IMPROVE the SBA Act

ACCESS TO CAPITAL JOBS Act 4.0: Continue to support this legislative package of access to capital measures and regulatory improvements introduced by Senator Pat Toomey (R-PA). Improving Crowdfunding Rules: Continue to express support for enhancements to equity and debt-based crowdfunding (Title III crowdfunding) that would lower costs, unleash additional capital, and improve reporting and regulatory compliance for startups and small businesses. Connecting Small Business to Capital Act (H.R. 945): Support the legislation. TAX AND SPENDING POLICY R&D Tax Credits: Advocated for the restoration of the R&D tax credit and its improvement for startups and small businesses. "Inflation Reduction Act" (IRA): Opposed the legislation, as it raises business taxes and fuels inflationary pressures through new government spending. Specifically, in IRA: Expressed concern and opposition to: the various tax increases including corporate taxes, extending the limitation on Main Street pass-through businesses to claim losses for two years without extending the 20% small business deduction; the size of the spending package and its impact on inflation and fiscal condition of the federal government; price controls on drugs; and the new spending for the IRS without implementing needed reforms and checks. Tax Cuts and Jobs Act (TCJA): Continue to express support for the permanency of various provisions of the TCJA including Section 199A, lower personal tax rates, expensing provisions and estate tax changes. Main Street Certainty Act, H.R. 1381/S. 480: Continue to support the advancement of this bill to make permanent the 20% small business deduction in the Tax Cuts and Jobs Act. EBITDA: Continue to support the reinstatement of the IBITDA standard for business interest deductions. Renewing Investment in American Workers and Supply Chains Act, H.R. 7229/S.4012: Support this legislation to allow accelerated depreciation for all structures. "Wealth Taxes:" Continue to oppose various schemes to tax wealth based on unrealized gains on property. REGULATION AND COMPETITION POLICY Fair and Open Competition Act, S. 403/H.R. 1284: Continue to support this legislation, which would prevent the Administration from using project labor agreement (PLAs) in federal procurement contracts. Project Labor Agreements (PLAs): Continue to express opposition to President Bidens Executive Order on the use of PLAs on federal procurement projects, including the bipartisan infrastructure package. Employee Rights Act, S.3889: Continue to support this bill introduced by Senator Tim Scott to protect the status of independent contractors. New Overtime Rules: Continue to express concern about DOL efforts to again alter overtime rules. Independent Contractor Rule: Continue to express general support for streamlining and modernizing the independent contractor rule and oppose proposals that would make many independent workers inappropriately (and against their will and wishes) categorized at employees. Submitted comments to the Department of Labor regarding the proposed Employee or Independent Contractor Classification Under the Fair Labor Standards Act (FLSA), 87 Fed. Reg. 62218, and urged them to withdraw the proposal and allow a March 2021 rule to stand. Joint Employer: Expressed concern for changing "joint employer" rules as they were recently improved and modernized. Submitted comments to the National Labor Relations Board (NLRB) urging a withdrawal of the proposed Standard for Determining Joint-Employer Status, 87 Fed. Reg. 54641. Franchise Rule: Have expressed support for the current franchise rule as it is undergoing a periodic decennial review by the Federal Trade Commission (FTC). Mergers and Acquisitions (M&A): Continue to express concern about Federal Trade Commission and Department of Justice action and changes to the regulatory framework governing M&A review and how this would impact the innovation and startup ecosystem in the United States. President Biden Competition Executive Order: Continue to express concerns about the premise and actions behind the EO to regulate and micro-manage various sectors of the economy including technology, energy, bio-pharmaceuticals, telecommunications, railroads and other sectors that are dominated by small-to-mid-size businesses (SMBs). Targeted Tech Legislation and Anti-Trust: Continue to express concerns about the impact and unintended consequences of legislation, regulation and anti-trust re-writes at the Federal Trade Commission (FTC) aimed at big tech and how it would impact small business access to markets and capital, and the entrepreneurial and innovation ecosystem in general. American Innovation and Online Choice Act, S.2992: Oppose the legislation. Platform Competition and Opportunity Act, H.R. 3826/S.3197: Oppose the legislation. Energy and Gas Prices: Continue to express concern about restrictive energy policies with respect to developing energy in the U.S. and how such restrictions are contributing to higher energy prices. Continue to express concern about the potential for higher taxes on this sector via a "windfall profits tax," restrictions and limitations placed on energy development on public lands, and red tape and lengthy reviews for permits and energy infrastructure projects. Electronic Payments and Credit Card Regulation: Continue to voice concern about new regulations on the payments system, specifically credit routing requirements and how they undermine payment-systems innovation that has provided small businesses a lifeline during the pandemic and payments options for small businesses and startups. Expressed opposition to the Credit Card Competition Act of 2022. Privacy Policy and Legislation: Support a national framework for privacy that is inclusive and equitable to all industries. Expressed areas where the "American Data Privacy and Protection Act" (H.R. 8152) could be improved for small businesses. Filed Joint comments with the FTC expressing concerns with an Advanced Notice of Proposed Rulemaking pertaining to so-called commercial surveillance and lax security practices. Railroad Strike: Supported H.J. Res 100 to avoid a rail strike. Expressed concern about the potential for a rail strikes and its impact on supply chains, inflation and economic disruption in general. Implementation of the "Corporate Transparency Act": Continue to express concerns about the impact of the legislation (and implementing regulations) on small businesses. AFFORDABLE AND COMPETITIVE HEALTH COVERAGE Affordability/More Choices: Continue to urge members of Congress and the Administration to advance market-oriented reforms that will lower health coverage costs for small businesses and increase choices in the marketplace like improved health savings accounts, support for transitional plans and local-direct health care. Oppose efforts, generally, to impose new mandates and taxes that will add to small business costs and reduce access to health care. Price Controls on Drugs: Continue to express concern about the impact of price controls on drugs either through Medicare negotiation, an international pricing mechanism, drug importation, and the effort to use march-in rights under the Bayh-Dole Act. Virtual Health Care and Telehealth: Urged Congress to reinstate virtual care access advanced during COVID-19 that enabled employers and health plans to provide pre-deductible coverage for telehealth services for individuals with HDHP-HSAs. ACCESS TO BROADBAND Extending America's Spectrum Leadership Act (H.R. 7783): SBE Council supported the legislation. Continue to express support for freeing up spectrum to allow next gen broadband (such as 5G) to be more available to communities nationwide. NTIA Rules on the Infrastructure Package: Continue to urge the adoption of simple, transparent rules and practices to ensure the effectiveness of these programs and taxpayer resources in delivering broadband to those lacking access, and to avoid waste and abuse of funds. INTELLECTUAL PROPERTY RIGHTS AND PROTECTIONS World Health Organization COVID IP Waiver: Continue to express opposition to the Biden Administrations support of a petition before the World Trade Organization that would waive vital intellectual property (IP) rights for COVID-19 vaccines and US innovators, which would essentially undercut American IP rights for U.S.-made innovations. Bayh-Dole Act: Continue to express support for the principals and rational behind Bayh-Dole (which strengthened IP rights) and against effort to undermine its effectiveness such as the misuse of march-in rights to take away IP protections. TRADE & GLOBAL MARKET ACCESS Trade Agreements: Continue to push for U.S. leadership on trade deals and opening global markets for U.S. businesses. International Trade Commission: Support general reforms that prevent foreign companies from abusing loopholes that undermine U.S. businesses and competitiveness. GOOD GOVERNMENT Improve the SBA Act (H.R. 7628): SBE Council continues to supports the legislation. Monetary Policy: Continue to express the need for the Federal Reserve to rein in the supply of money, and leave interest rates to the market. Workforce Policy/Access to Skilled Labor Continue to express support for policies that will increase the supply of labor and skilled labor such as immigration reform, new service-sector visas, second-chance initiatives, improving the earned-income tax credit, and fixing penalties on social security benefits for those who return to work. Commission on the American Workforce Act (H.R. 8784): Support the legislation.

Client expense: $35,000 · Firm income: Not reported

Government targets: Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Natl Labor Relations Board (NLRB), SENATE, Securities & Exchange Commission (SEC)

ACCESS TO CAPITAL JOBS Act 4.0: Continue to support this legislative package of access to capital measures and regulatory improvements introduced by Senator Pat Toomey (R-PA). Improving Crowdfunding Rules: Continue to express support for enhancements to equity and debt-based crowdfunding (Title III crowdfunding) that would lower costs, unleash additional capital, and improve reporting and regulatory compliance for startups and small businesses. TAX AND SPENDING POLICY Build Back Better Act (BBB)"/"Inflation Reduction Act" (IRA): Opposed this variation of BBB that raises taxes and fuels inflationary pressures through new government spending. Specifically, in IRA: Expressed concern and opposition to: the various tax increases including corporate taxes, tax changes to carried interest and extending the limitation on Main Street pass-through businesses to claim losses for two years without extending the 20% small business deduction; the size of the spending package and its impact on inflation and fiscal condition of the federal government; price controls on drugs; and the new spending for the IRS without implementing needed reforms and checks. Tax Cuts and Jobs Act (TCJA): Continue to express support for the permanency of various provisions of the TCJA including Section 199A, lower personal tax rates, expensing provisions and estate tax changes. Main Street Certainty Act, H.R. 1381/S. 480: Continue to support the advancement of this bill to make permanent the 20% small business deduction in the Tax Cuts and Jobs Act. Renewing Investment in American Workers and Supply Chains Act, H.R. 7229/S.4012: Support this legislation to allow accelerated depreciation for all structures. "Wealth Taxes:" Continue to oppose various schemes to tax wealth based on unrealized gains on property. REGULATION AND COMPETITION POLICY Fair and Open Competition Act, S. 403/H.R. 1284: Continue to support this legislation, which would prevent the Administration from using project labor agreement (PLAs) in federal procurement contracts. Project Labor Agreements (PLAs): Continue to express opposition to President Bidens Executive Order on the use of PLAs on federal procurement projects, including the bipartisan infrastructure package. Employee Rights Act, S.3889: Continue to support this bill introduced by Senator Tim Scott to protect the status of independent contractors. New Overtime Rules: Continue to express concern about changing overtime rules. Independent Contractor Rule: Continue to express general support for streamlining and modernizing the independent contractor rule, and oppose proposals that would make many independent workers inappropriately (and against their will and wishes) categorized at employees. Joint Employer: Expressed concern for changing "joint employer" rules as they were recently improved and modernized. Franchise Rule: Have expressed support for the current franchise rule as it is undergoing a periodic decennial review by the Federal Trade Commission (FTC). SEC Climate Disclosure Rule: Filed joints comments against the rule, and its costs, complexity and unworkability for small businesses. Mergers and Acquisitions (M&A): Continue to express concern about Federal Trade Commission and Department of Justice action and changes to the regulatory framework governing M&A review and how this would impact the innovation and startup ecosystem in the United States. President Biden Competition Executive Order: Continue to express concerns about the premise and actions behind the EO to regulate and micro-manage various sectors of the economy including technology, energy, bio-pharmaceuticals, telecommunications, railroads and other sectors that are dominated by small-to-mid-size businesses (SMBs). Targeted Tech Legislation and Anti-Trust: Continue to express concerns about the impact and unintended consequences of legislation, regulation and anti-trust re-writes at the Federal Trade Commission (FTC) aimed at big tech and how it would impact small business access to markets and capital, and the entrepreneurial and innovation ecosystem in general. American Innovation and Online Choice Act, S.2992: Oppose the legislation. Platform Competition and Opportunity Act, H.R. 3826/S.3197: Oppose the legislation. Energy and Gas Prices: Continue to express concern about restrictive energy policies with respect to developing energy in the U.S. and how such restrictions are contributing to higher energy prices. Continue to express concern about the potential for higher taxes on this sector via a "windfall profits tax," restrictions and limitations placed on energy development on public lands, and red tape and lengthy reviews for permits and energy infrastructure projects. Electronic Payments and Credit Card Regulation: Continue to voice concern about new regulations on the payments system, specifically credit routing requirements and how they undermine payment-systems innovation that has provided small businesses a lifeline during the pandemic and payments options for small businesses and startups. Expressed opposition to the Credit Card Competition Act of 2022. Privacy Policy and Legislation: Support a national framework for privacy that is inclusive and equitable to all industries. Expressed areas where the "American Data Privacy and Protection Act" (H.R. 8152) could be improved for small businesses. Railroad Strike: Expressed concern about the potential for a rail strikes and its impact on supply chains, inflation and economic disruption in general. AFFORDABLE AND COMPETITIVE HEALTH COVERAGE Affordability/More Choices: Continue to urge members of Congress and the Administration to advance market-oriented reforms that will lower health coverage costs for small businesses and increase choices in the marketplace like improved health savings accounts, support for transitional plans and local-direct health care. Oppose efforts, generally, to impose new mandates and taxes that will add to small business costs and reduce access to health care. Price Controls on Drugs: Continue to express opposition to efforts that place price controls on drugs either through Medicare negotiation, an international pricing mechanism, drug importation, and the misdirected effort to use march-in rights under the Bayh-Dole Act. Virtual Health Care and Telehealth: Urged Congress to reinstate virtual care access advanced during COVID-19 that enabled employers and health plans to provide pre-deductible coverage for telehealth services for individuals with HDHP-HSAs. ACCESS TO BROADBAND Extending America's Spectrum Leadership Act (H.R. 7783): SBE Council supported the legislation. NTIA Rules on the Infrastructure Package: Following our filing of comments before the National Telecommunications and Information Administration on the Broadband Equity, Access, and Development (BEAD) and Digital Equity Planning Grant programs in the infrastructure package, we continue to urge the adoption of simple, transparent rules and common-sense principles to ensure the effectiveness of these programs in delivering broadband to those lacking access, and to avoid waste and abuse of funds. Spectrum: Continue to express support for and the need to unleash mid-band spectrum in order to enable 5G rollout and deployment across the country. INTELLECTUAL PROPERTY RIGHTS AND PROTECTIONS World Health Organization COVID IP Waiver: Continue to express opposition to the Biden Administrations support of a petition before the World Trade Organization that would waive vital intellectual property (IP) rights for COVID-19 vaccines and US innovators, which would essentially undercut American IP rights for U.S.-made innovations. Bayh-Dole Act: Continue to express support for the principals and rational behind Bayh-Dole (which strengthened IP rights) and against effort to undermine its effectiveness such as the misuse of march-in rights to take away IP protections. TRADE & GLOBAL MARKET ACCESS Trade Agreements: Continue to push for U.S. leadership on trade deals and opening global markets for U.S. businesses. Moratorium on Customs Duties and Electronic Transmissions: SBE Council supported the renewing of the moratorium before the World Trade Organization (WTO). GOOD GOVERNMENT Improve the SBA Act (H.R. 7628): SBE Council supports the legislation. Monetary Policy: Continue to express the need for the Federal Reserve to rein in the supply of money, and leave interest rates to the market. Workforce Policy/Access to Skilled Labor Continue to express support for policies that will increase the supply of labor and skilled labor such as immigration reform, new service-sector visas, improving the earned-income tax credit, and fixing penalties on social security benefits for those who return to work.

Protect the credit union tax exemption; Oppose S. 4698, the Improving Cybersecurity of Credit Unions Act- Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; support S. 4165; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; extend GLBA like data security measures to retailers; recognized GLBA compliance in any privacy legislation; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for S.4879/H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412/S.4522, the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; oppose NCUA proposed rule on Succession Planning (RIN: 3133-AF42); general support for Re-Proposal to Enhance Eligibility Requirements for Enterprise Single-Family Seller/Servicers; need greater clarity regarding Guidelines for Evaluating Account and Services Requests (Docket No. Docket No. OP-1747); adopt more flexible rules for acceptance and delivery of electronic signatures and disclosures; support for CFPB commission rather than single director; support for H.R. 7628, the Improve the SBA Act; Asset Threshold for Determining the Appropriate Supervisory Office (RIN: 3133-AF41) - specialized oversight of larger credit unions should be calibrated to reflect relative risk to the SIF today and not defined using an outdated asset threshold; provide greater flexibility related to Permissible Interest Rate Ceiling; NCUA should practice restraint regarding budgeting and be more transparent; support for alternative credit scoring models; not sufficient evidence to justify development of CBDC; do not let the NFIP lapse; the NCUA should eliminate the internal written loan participation policy requirements found at 701.22(b)(5)(iv); HUD should allow the option of 40-year mortgage loans; support for HR6889/S. 4325, the Credit Union Board Modernization Act; improve Veterans access to capital by exempting credit unions' business loans to veterans from the MBL cap; expand the definition of Community Financial Institutions (CFIs) in the Federal Home Loan Bank Act (FHLB Act) to include credit unions and Treasury-certified non-depository community development financial institutions; make permanent NCUAs authorities for the Central Liquidity Facility (CLF) granted under the CARES Act; support for H.R. 5912, the Close the ILC Loophole Act; support for H.R. 7733, the CDFI Bond Guarantee Program Improvement Act; support H.R. 3962, the SECURE Notarization Act; opposition to H.R. 4277, the Overdraft Protection Act; H.R. 6814, the Small Business Fair Debt Collection Protection Act - the FDCPA changes should not improperly burden creditors; opposed to the following 2 bills in their current form: H.R. 7022, the Strengthening Cybersecurity for the Financial Sector Act, and H.R. 8152, the American Data Privacy and Protection Act, Excluding bank lease provision from S. 4543, the FY 2023 NDAA; support for H.R. 5911, the Fair Hiring in Banking Act (as an amendment to H.R. 7900, the FY 2023 NDAA); support for H.R. 3958, the Central Liquidity Facility Enhancement Act; support for H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support for FY 2023 FSGG appropriations in H.R. 8294; oppose interchange legislation: S. 4674/H.R. 8874, the Credit Card Competition Act of 2022; opposed to H.R. 8485, the Expanding Access to Credit through Consumer-Permissioned Data Act; Comments to Department of Commerce related to RIN 0625-XC04; NCUA Regulations Part 701.36, Occupancy Rule; NCUA 2022 Mid-Session Budget; Comments to CFPB related to Docket No. CFPB-2022-0039; Petition to CFPB on rulemaking for larger participants in aggregation services market; Comments to FinCEN related to RIN No.: 1506- AB55; Comments to Treasury related to Request for Comment Document No. 2022-14588; Comments to NCUA related to 2022 Regulatory Review; Opposing expansion of Regulation E liability; Comments to FCC related to Docket No. FCC 21-105; Comments to CFPB related to Docket No. CFPB-2022-0040; Comments to Federal Reserve related to Docket No. R-1775; Deadline extension request for Docket No. CFPB-2022-0048; NCUA Simplified CECL Tool; Comments to NCUA related to RIN 3133-AF47; FHFA oversight - support incorporation of climate change into GSE/FHFA governance, Supporting appraisal modernization, and Supporting CDFI mortgage programs.

Protect the credit union tax exemption; Oppose S. 4698, the Improving Cybersecurity of Credit Unions Act- Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; support S. 4165; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; extend GLBA like data security measures to retailers; recognized GLBA compliance in any privacy legislation; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for S.4879/H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412/S.4522, the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; oppose NCUA proposed rule on Succession Planning (RIN: 3133-AF42); general support for Re-Proposal to Enhance Eligibility Requirements for Enterprise Single-Family Seller/Servicers; need greater clarity regarding Guidelines for Evaluating Account and Services Requests (Docket No. Docket No. OP-1747); adopt more flexible rules for acceptance and delivery of electronic signatures and disclosures; support for CFPB commission rather than single director; support for H.R. 7628, the Improve the SBA Act; Asset Threshold for Determining the Appropriate Supervisory Office (RIN: 3133-AF41) - specialized oversight of larger credit unions should be calibrated to reflect relative risk to the SIF today and not defined using an outdated asset threshold; provide greater flexibility related to Permissible Interest Rate Ceiling; NCUA should practice restraint regarding budgeting and be more transparent; support for alternative credit scoring models; not sufficient evidence to justify development of CBDC; do not let the NFIP lapse; the NCUA should eliminate the internal written loan participation policy requirements found at 701.22(b)(5)(iv); HUD should allow the option of 40-year mortgage loans; support for HR6889/S. 4325, the Credit Union Board Modernization Act; improve Veterans access to capital by exempting credit unions' business loans to veterans from the MBL cap; expand the definition of Community Financial Institutions (CFIs) in the Federal Home Loan Bank Act (FHLB Act) to include credit unions and Treasury-certified non-depository community development financial institutions; make permanent NCUAs authorities for the Central Liquidity Facility (CLF) granted under the CARES Act; support for H.R. 5912, the Close the ILC Loophole Act; support for H.R. 7733, the CDFI Bond Guarantee Program Improvement Act; support H.R. 3962, the SECURE Notarization Act; opposition to H.R. 4277, the Overdraft Protection Act; H.R. 6814, the Small Business Fair Debt Collection Protection Act - the FDCPA changes should not improperly burden creditors; opposed to the following 2 bills in their current form: H.R. 7022, the Strengthening Cybersecurity for the Financial Sector Act, and H.R. 8152, the American Data Privacy and Protection Act, Excluding bank lease provision from S. 4543, the FY 2023 NDAA; support for H.R. 5911, the Fair Hiring in Banking Act (as an amendment to H.R. 7900, the FY 2023 NDAA); support for H.R. 3958, the Central Liquidity Facility Enhancement Act; support for H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support for FY 2023 FSGG appropriations in H.R. 8294; oppose interchange legislation: S. 4674/H.R. 8874, the Credit Card Competition Act of 2022; opposed to H.R. 8485, the Expanding Access to Credit through Consumer-Permissioned Data Act; Comments to Department of Commerce related to RIN 0625-XC04; NCUA Regulations Part 701.36, Occupancy Rule; NCUA 2022 Mid-Session Budget; Comments to CFPB related to Docket No. CFPB-2022-0039; Petition to CFPB on rulemaking for larger participants in aggregation services market; Comments to FinCEN related to RIN No.: 1506- AB55; Comments to Treasury related to Request for Comment Document No. 2022-14588; Comments to NCUA related to 2022 Regulatory Review; Opposing expansion of Regulation E liability; Comments to FCC related to Docket No. FCC 21-105; Comments to CFPB related to Docket No. CFPB-2022-0040; Comments to Federal Reserve related to Docket No. R-1775; Deadline extension request for Docket No. CFPB-2022-0048; NCUA Simplified CECL Tool; Comments to NCUA related to RIN 3133-AF47; FHFA oversight - support incorporation of climate change into GSE/FHFA governance, Supporting appraisal modernization, and Supporting CDFI mortgage programs.

ACCESS TO CAPITAL JOBS Act 4.0: Support this legislative package of access to capital measures and regulatory improvements introduced by Senator Pat Toomey (R-PA). TAX AND SPENDING POLICY Build Back Better Act (BBB): Opposed new variations of BBB that raise taxes on small-to-mid size businesses and fuel inflationary pressures through government spending. Specifically, in Build Back Better: Expressed concern and opposition to: the various tax increases on SMBs including death and new wealth taxes, eliminating stepped-up basis, increasing the personal rates, and applying the Net Investment Income Tax to active owners of small businesses; the size of the spending package and its impact on inflation and fiscal condition of the federal government; price controls on drugs in the legislation; and regulatory initiatives that would raise costs for small employers in the workplace. Tax Cuts and Jobs Act (TCJA): Continue to express support for the permanency of various provisions of the TCJA including Section 199A, lower personal tax rates, expensing provisions and estate tax changes. Main Street Certainty Act, H.R. 1381/S. 480: Continue to support the advancement of this bill to make permanent the 20% small business deduction in the Tax Cuts and Jobs Act. Renewing Investment in American Workers and Supply Chains Act, H.R. 7229/S.4012: Support this legislation to allow accelerated depreciation for all structures. REGULATION AND COMPETITION POLICY Fair and Open Competition Act, S. 403/H.R. 1284: Support the legislation, which would prevent the Administration from using project labor agreement (PLAs) in federal procurement contracts. Project Labor Agreements (PLAs): Continue to express opposition to President Bidens Executive Order on the use of PLAs on federal procurement projects, including the bipartisan infrastructure package. Employee Rights Act, S.3889: Continue to support this bill introduced by Senator Tim Scott to protect the status of independent contractors. New Overtime Rules: Continue to express concern about changing overtime rules. Independent Contractor Rule: Continue to express general support for streamlining and modernizing the independent contractor rule, and oppose proposals that would make many independent workers inappropriately (and against their will and wishes) categorized at employees. Mergers and Acquisitions (M&A): Filed comments expressing concern to the Federal Trade Commission and Department of Justice about potential changes to the regulatory framework governing M&A review and how this would impact the innovation and startup ecosystem in the United States. Private Fund Advisers Rule: Submitted comments to the Securities and Exchange Commission that urged the agency to refrain from moving forward with a proposed rule, as the Commission did not cite any instance of market failure, and the fact that the new rule would curtail investment activity and disproportionately harm smaller, and women and minority-owned firms. The Franchise Rule: Expressed support for the current rule, as the Federal Trade Commission embarks upon a decennial review of the rule. President Biden Competition Executive Order: Continue to express concerns about the premise and actions behind the EO to regulate and micro-manage various sectors of the economy including technology, energy, bio-pharmaceuticals, telecommunications, railroads and other sectors that are dominated by small-to-mid-size businesses (SMBs). Targeted Tech Legislation and Anti-Trust: Continue to express concerns about the impact and unintended consequences of legislation, regulation and anti-trust re-writes at the Federal Trade Commission (FTC) aimed at big tech and how it would impact small business access to markets and capital, and the entrepreneurial and innovation ecosystem in general. American Innovation and Online Choice Act, S.2992: Oppose the legislation. Platform Competition and Opportunity Act, H.R. 3826/S.3197: Oppose the legislation. Energy and Gas Prices: Continue to express concern about restrictive energy policies with respect to developing energy in the U.S. and how such restrictions are contributing to higher energy prices. For example, expressed concern about the potential for higher taxes on this sector via a "windfall profits tax," restrictions and limitations placed on energy development on public lands, and red tape and lengthy reviews for permits and energy infrastructure projects. Electronic Payments: Continue to voice concern about new regulations on the payments system, specifically credit routing requirements and how they undermine payment-systems innovation that has provided small businesses a lifeline during the pandemic and payments options for small businesses and startups. Privacy Policy and Legislation: Support a national framework for privacy that is inclusive and equitable to all industries. Expressed areas where the "American Data Privacy and Protection Act" (H.R. 8152) could be improved for small businesses. Re-regulation of Railroads: Delivered our views to the House Transportation and Infrastructure Committee members about how rules promoting forced/switching - forced/access - and crew sizes will disrupt this sector and the healing of supply chains. AFFORDABLE AND COMPETITIVE HEALTH COVERAGE Affordability/More Choices: Continue to urge members of Congress and the Administration to advance market-oriented reforms that will lower health coverage costs for small businesses and increase choices in the marketplace like improved health savings accounts, support for transitional plans and local-direct health care. Oppose efforts, generally, to impose new mandates and taxes that will add to small business costs and reduce access to health care. Price Controls on Drugs: Continue to express opposition to efforts that place price controls on drugs either through Medicare negotiation, an international pricing mechanism, drug importation, and the misdirected effort to use march-in rights under the Bayh-Dole Act. Virtual Health Care and Telehealth: Urged Congress to reinstate virtual care access advanced during COVID-19 that enabled employers and health plans to provide pre-deductible coverage for telehealth services for individuals with HDHP-HSAs. ACCESS TO BROADBAND Extending America's Spectrum Leadership Act (H.R. 7783): SBE Council supports the legislation. NTIA Rules on the Infrastructure Package: Following our filing of comments before the National Telecommunications and Information Administration on the Broadband Equity, Access, and Development (BEAD) and Digital Equity Planning Grant programs in the infrastructure package, we continue to urge the adoption of simple, transparent rules and common-sense principles to ensure the effectiveness of these programs in delivering broadband to those lacking access, and to avoid waste and abuse of funds. INTELLECTUAL PROPERTY RIGHTS AND PROTECTIONS World Health Organization COVID IP Waiver: Continue to express opposition to the Biden Administrations support of a petition before the World Trade Organization that would waive vital intellectual property (IP) rights for COVID-19 vaccines and US innovators, which would essentially undercut American IP rights for U.S.-made innovations. Bayh-Dole Act: Continue to express support for the principals and rational behind Bayh-Dole (which strengthened IP rights) and against effort to undermine its effectiveness such as the misuse of march-in rights to take away IP protections. TRADE & GLOBAL MARKET ACCESS Trade Agreements: Continue to push for U.S. leadership on trade deals and opening global markets for U.S. businesses. Moratorium on Customs Duties and Electronic Transmissions: SBE Council supported the renewing of the moratorium before the World Trade Organization (WTO). NOMINATIONS Don Cravens as Undersecretary of the Minority Business Development Agency: Support the Nomination currently before the U.S. Senate. GOOD GOVERNMENT Improve the SBA Act (H.R. 7628): SBE Council supports the legislation.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; support S. 4165; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; extend GLBA like data security measures to retailers; recognized GLBA compliance in any privacy legislation; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412/S.4522, the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; oppose NCUA proposed rule on Succession Planning (RIN: 3133-AF42); general support for Re-Proposal to Enhance Eligibility Requirements for Enterprise Single-Family Seller/Servicers; need greater clarity regarding Guidelines for Evaluating Account and Services Requests (Docket No. Docket No. OP-1747); adopt more flexible rules for acceptance and delivery of electronic signatures and disclosures; support for CFPB commission rather than single director; support for H.R. 7628, the Improve the SBA Act; Asset Threshold for Determining the Appropriate Supervisory Office (RIN: 3133-AF41) - specialized oversight of larger credit unions should be calibrated to reflect relative risk to the SIF today and not defined using an outdated asset threshold; provide greater flexibility related to Permissible Interest Rate Ceiling; NCUA should practice restraint regarding budgeting and be more transparent; support for alternative credit scoring models; not sufficient evidence to justify development of CBDC; do not let the NFIP lapse; the NCUA should eliminate the internal written loan participation policy requirements found at 701.22(b)(5)(iv); HUD should allow the option of 40-year mortgage loans; support for S. 4325, the Credit Union Board Modernization Act; improve Veterans access to capital by exempting credit unions' business loans to veterans from the MBL cap; expand the definition of Community Financial Institutions (CFIs) in the Federal Home Loan Bank Act (FHLB Act) to include credit unions and Treasury-certified non-depository community development financial institutions; make permanent NCUAs authorities for the Central Liquidity Facility (CLF) granted under the CARES Act; support for H.R. 5912, the Close the ILC Loophole Act; support for H.R. 7733, the CDFI Bond Guarantee Program Improvement Act; support H.R. 3962, the SECURE Notarization Act; opposition to H.R. 4277, the Overdraft Protection Act; H.R. 6814, the Small Business Fair Debt Collection Protection Act - the FDCPA changes should not improperly burden creditors; opposed to the following 2 bills in their current form: H.R. 7022, the Strengthening Cybersecurity for the Financial Sector Act, and H.R. 8152, the American Data Privacy and Protection Act.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; support S. 4165; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; extend GLBA like data security measures to retailers; recognized GLBA compliance in any privacy legislation; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412/S.4522, the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; oppose NCUA proposed rule on Succession Planning (RIN: 3133-AF42); general support for Re-Proposal to Enhance Eligibility Requirements for Enterprise Single-Family Seller/Servicers; need greater clarity regarding Guidelines for Evaluating Account and Services Requests (Docket No. Docket No. OP-1747); adopt more flexible rules for acceptance and delivery of electronic signatures and disclosures; support for CFPB commission rather than single director; support for H.R. 7628, the Improve the SBA Act; Asset Threshold for Determining the Appropriate Supervisory Office (RIN: 3133-AF41) - specialized oversight of larger credit unions should be calibrated to reflect relative risk to the SIF today and not defined using an outdated asset threshold; provide greater flexibility related to Permissible Interest Rate Ceiling; NCUA should practice restraint regarding budgeting and be more transparent; support for alternative credit scoring models; not sufficient evidence to justify development of CBDC; do not let the NFIP lapse; the NCUA should eliminate the internal written loan participation policy requirements found at 701.22(b)(5)(iv); HUD should allow the option of 40-year mortgage loans; support for S. 4325, the Credit Union Board Modernization Act; improve Veterans access to capital by exempting credit unions' business loans to veterans from the MBL cap; expand the definition of Community Financial Institutions (CFIs) in the Federal Home Loan Bank Act (FHLB Act) to include credit unions and Treasury-certified non-depository community development financial institutions; make permanent NCUAs authorities for the Central Liquidity Facility (CLF) granted under the CARES Act; support for H.R. 5912, the Close the ILC Loophole Act; support for H.R. 7733, the CDFI Bond Guarantee Program Improvement Act; support H.R. 3962, the SECURE Notarization Act; opposition to H.R. 4277, the Overdraft Protection Act; H.R. 6814, the Small Business Fair Debt Collection Protection Act - the FDCPA changes should not improperly burden creditors; opposed to the following 2 bills in their current form: H.R. 7022, the Strengthening Cybersecurity for the Financial Sector Act, and H.R. 8152, the American Data Privacy and Protection Act.