TAILOR Act

Protect the credit union tax exemption; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Support regulatory relief for credit unions; Provide guidance or rulemakings rather than rule through enforcement; Support increase in funding for CDFI Fund, MDIs, and the CDRLF; 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; Support extending GLBA like data security measures to retailers; Support recognizing GLBA compliance in any privacy legislation; Oppose SBA direct lending authority; Support improvements to ease the process for forgiveness of PPP loans to small businesses; Oppose limits on fee income for credit unions including courtesy pay; Support CFPB study of overdraft programs to determine the value to consumers; Support limiting burdens of HMDA rule on credit unions; CFPB should remove unnecessary and unused data points related to HMDA reporting; Support permanently increasing reporting thresholds for open- and closed-end loans; Prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; CFPB should engage in interagency coordination on Section 1033 consumer access to financial records rulemaking; Oppose CFPBs characterization of regulated and disclosed financial services fees as junk fees; CFPB should explore streamlining required fee disclosures; CFPB should clarify UDAAP authority; CFPB should respect GLBAs data security regulatory structure; CFPB should limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); Improve examination coordination between CFPB and NCUA; Support permanent adoption of CFPBs expired temporary relief of E-SIGN regulation; Support CFPB exercise of larger participant authority to oversee fintech companies; Support fair distribution of Regulation E error resolution responsibilities; Support clear regulatory framework for digital assets to encourage responsible innovation and permit credit union participation; Support CDFI Fund transparency on certification changes; Support streamlining and modernization of CDFI Fund certification process; Support Congressional oversight of SBAs Affiliation and Small Business Lending Company proposed rules; Support tax deduction for mortgage insurance premiums; Support modification or removal of the credit union member business lending cap; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; Support alternative credit scoring models; Oppose development of a CBDC; Support prevention of an NFIP lapse; Support improving veterans access to capital by exempting credit unions business loans to veterans from the credit union member business lending cap; Support expanding 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; Oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; Support parity for credit unions related to stablecoin regulation; Treasury should address the demand for coins to help consumers who rely on cash transactions; Support addressing appraisal bias and modernize the appraisal process for consistency; Support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support easing requirements for de novo credit unions; Support providing flexibility for credit unions to issue subordinated debt; Support H.R. 5189, the Member Business Loan Expansion Act; Support the Federal Home Loan Banks' Mission Implementation Act (H.R. 3323, S.1684); Support H.R. 4773, the Consumer Financial Protection Commission Act; Oppose legislation granting NCUA third-party vendor examination authority (H.R. 7022, S. 4698); Oppose Credit Card Competition Act (H.R. 8874, S. 4674); Support SAFE Banking Act (H.R. 1996, S. 910); Support Central Liquidity Facility Enhancement Act (H.R. 3958, S. 5183); Support Credit Union Board Modernization Act (H.R. 6889, S. 4325); Support Expanding Financial Access for Underserved Communities Act (H.R. 7003, S. 4879); Support CDFI Bond Guarantee Program Improvement Act (H.R. 7733, S. 3441); Support Title III, Subtitle C of H.R. 2543 - Promoting and Advancing Communities of Color Through Inclusive Lending; Support S. 3590, the Middle Class Mortgage Insurance Premium Act; Oppose inclusion of the Credit Card Competition Act (H.R. 8874, S. 4674) or NCUA third-party vendor examination authority (H.R. 7022, S. 4698) in the FY 2023 NDAA; Support H.R. 5912, the Close the ILC Loophole Act; Support S. 762, the Expanding Access to Lending Options Act; Oppose Senate NDAA amendments 6201 and 6174 on credit card interchange; Support S. 4165, the CDFI Crisis Fund Act; Oppose H.R. 4277, the Overdraft Protection Act; Oppose FDCPA changes that improperly burden creditors in H.R. 6814, the Small Business Fair Debt Collection Protection Act; Oppose inclusion of bank lease provision in FY 2023 NDAA; Oppose H.R. 8152, the American Data Privacy and Protection Act; Support H.R. 5911, the Fair Hiring in Banking Act; Support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; Oppose H.R. 8485, the Expanding Access to Credit through Consumer-Permissioned Data Act; Support the Small LENDER Act (H.R. 6732, S. 4004); Support H.R. 7628, the Improve the SBA Act; Support the SECURE Notarization Act (H.R. 3962, S. 1625); Support the TAILOR Act (H.R. 766, S. 3745); Support the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act (H.R. 7412, S.4522); Support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; Oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; Support S. 5189, the Close the Shadow Banking Loophole Act; Support for Advancing Technologies to Support Inclusion Act discussion draft; Support for Creation of Diverse and Mission-Driven Community Financial Institutions Act discussion draft; Comments to SBA on RIN 3245-AH87 expressing concern about interaction between Affiliation and Small Business Lending Company proposed rules; Request for extension of temporary NCUA relief on loan participation and eligible obligation regulations due to the COVID-19 pandemic; Request for clarification of CFPB authority and intention for auto loan data collection; Comments to Treasury Dept on Docket No. 2022-21524 requesting streamlined applications for federal community investment programs; Comments to CDFI Fund on Docket No. 2022-22767 requesting modification of proposed pre-approved Target Market assessment methodologies; Comments to EPA on Docket ID No. EPA-HQ-OA-2022-0859 opposing establishment of single national green bank and supporting credit union inclusion as indirect recipients of Greenhouse Gas Reduction Fund disbursements; Comments to NCUA on RIN: 3133-AF43 supporting the elimination of the maximum maturity requirement for subordinated debt; Comments to CDFI Fund on Docket No. 2022-24082 opposing changes to CDFI certification requirements; Comments to NCUA on Docket No. NCUA-2022-0132 opposing overly complex member expulsion process; Support delay of GSEs credit fee caps effective date; Comments to CFPB on Docket No. CFPB-2022-0059 supporting additional flexibility in the Qualified Mortgage rule; Comments to FTC on R111004 opposing data privacy rulemaking absent comprehensive federal legislation; Support elimination of in-person quorum requirement for credit union annual meetings; Comments to CISA on Docket ID: CISA-2022-0010 supporting simplification of cyber incident reporting requirements; Support inclusion of 501(c)(19) veterans organizations as qualified charit[ies] in NCUA regulations; Comments to Treasury Department on Document No. 2022-20279 supporting application of Bank Secrecy Act and anti-money laundering regulations to digital assets and supporting interagency coordination to ensure credit union inclusion in digital asset regulations; Comments to FHFA on Federal Home Loan Bank System review supporting capital requirements for System members and supporting alignment of tangible capital definitions among regulators; Comments to FHFA on Fintech in Housing Finance supporting interagency coordination and caution in integration of non-depository fintech lenders; Comments to NCUA on RIN 3064-ZA33 supporting flexibility in updated commercial real estate loan accommodations policy statement; Oppose increases to NCUAs 2023-2024 budget and support increased budget transparency; Oppose expansion of Regulation E liability;

Client expense: $910,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, Veterans Affairs, Dept of (VA), White House Office

H.R. 133 Consolidated Appropriations Act, 2021 Economic Impact Payments H.R. 527 CFPB Dual Mandate and Economic Analysis Act H.R. 766 TAILOR Act H.R. 1319 American Rescue Plan Act of 2021 H.R. 1799 The PPP Extension Act H.R. 1996 SAFE Banking Act H.R. 2040 The Financial Reporting Modernization Act H.R. 2211 Central Bank Digital Currency Study Act H.J. Res. 25 Congressional disapproval of OCC True Lender Rule S. 49 No CFPB in PPP Act S. 524 A bill to create a Homeowner Assistance Fund at the Department of Treasury S. 563 Fair Access to Banking Act S. 723 PPP Extension Act S. 823 A bill to amend the American Rescue Plan Act of 2021 to provide for protection of recovery rebates. S. 910 SAFE Banking Act S.J. Res. 15 Congressional disapproval of OCC True Lender Rule Bank Capital and Accounting Relief Bank Secrecy Act/Anti-Money Laundering Rules/Legislation, including Beneficial Ownership Issue BitPay National Trust and Paxos National Trust OCC Trust Charter Applications Brokered Deposits Cannabis Banking CARES Act, Economic Impact Payments CARES Act, Paycheck Protection Program Implementation Central Bank Digital Currency/Digital Dollar Climate-Related Financial Regulation Community Bank Access to Capital Community Bank Leverage Ratio Community Development Financial Institutions (CDFI) Fund Appropriations Community Reinvestment Act Modernization Consumer Access to Financial Records Credit Reporting Credit Union Acquisitions of Community Banks Credit Union Business Lending Powers Credit Union Field of Membership Rules Credit Union Growth/Powers/Abusive Behavior Credit Union Supplemental Capital Cryptocurrency Current Expected Credit Losses (CECL) Customer Data Access, Implementation of Dodd Frank Act Section 1033 Cybersecurity Data Security, Breaches and Privacy De Novo Bank Formation Economic Impact Payments (EIP) Garnishment Exemption EIP - Recommendations for Improving Delivery of Payments to Americans Eliminating Corporate Shadow Banking Emergency Capital Investment Program Implementation Equal treatment between community banks and credit unions when assessing rent and related charges on military bases. Exclusion of Paycheck Protection Program Loans from Calculation of Bank Asset Thresholds Fed Accounts Figure Bank, NA Charter Application Fintech/Banking Relationships Fintech Regulatory Requirements Financial Data Sharing Safety Act First Blockchain Bank & Trust, N.A. Charter Application Flood Insurance Reauthorization GM Financial Bank Deposit Insurance Application Industrial Loan Corporation Loophole Reforms/ Square (ILC) and Rakuten Deposit Insurance Applications Interest Rate Caps Minority Depository Institutions Issues Mortgage Servicer Liquidity Facility Nomination of Isabel Guzman to serve as the Administrator of the U.S. Small Business Administration (SBA) Nomination of Dr. Janet Yellen to serve as Secretary of the Treasury OCC Interpretive Letter 1176/Protego & Anchorage Conversion Applications OCC Proposed Payments Charter Postal Banking Regulatory Burden Relief for Community Banks Regulatory and Tax Relief for Community Banks SBA 7(a) Loan Program Funding and Terms Troubled Debt Restructuring

Client expense: $910,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA), Treasury, Dept of

H.R. 133 Consolidated Appropriations Act, 2021 Economic Impact Payments H.R. 527 CFPB Dual Mandate and Economic Analysis Act H.R. 766 TAILOR Act H.R. 1319 American Rescue Plan Act of 2021 H.R. 1799 The PPP Extension Act H.R. 1996 SAFE Banking Act H.R. 2040 The Financial Reporting Modernization Act H.R. 2211 Central Bank Digital Currency Study Act H.J. Res. 25 Congressional disapproval of OCC True Lender Rule S. 49 No CFPB in PPP Act S. 524 A bill to create a Homeowner Assistance Fund at the Department of Treasury S. 563 Fair Access to Banking Act S. 723 PPP Extension Act S. 823 A bill to amend the American Rescue Plan Act of 2021 to provide for protection of recovery rebates. S. 910 SAFE Banking Act S.J. Res. 15 Congressional disapproval of OCC True Lender Rule Bank Capital and Accounting Relief Bank Secrecy Act/Anti-Money Laundering Rules/Legislation, including Beneficial Ownership Issue BitPay National Trust and Paxos National Trust OCC Trust Charter Applications Brokered Deposits Cannabis Banking CARES Act, Economic Impact Payments CARES Act, Paycheck Protection Program Implementation Central Bank Digital Currency/Digital Dollar Climate-Related Financial Regulation Community Bank Access to Capital Community Bank Leverage Ratio Community Development Financial Institutions (CDFI) Fund Appropriations Community Reinvestment Act Modernization Consumer Access to Financial Records Credit Reporting Credit Union Acquisitions of Community Banks Credit Union Business Lending Powers Credit Union Field of Membership Rules Credit Union Growth/Powers/Abusive Behavior Credit Union Supplemental Capital Cryptocurrency Current Expected Credit Losses (CECL) Customer Data Access, Implementation of Dodd Frank Act Section 1033 Cybersecurity Data Security, Breaches and Privacy De Novo Bank Formation Economic Impact Payments (EIP) Garnishment Exemption EIP - Recommendations for Improving Delivery of Payments to Americans Eliminating Corporate Shadow Banking Emergency Capital Investment Program Implementation Equal treatment between community banks and credit unions when assessing rent and related charges on military bases. Exclusion of Paycheck Protection Program Loans from Calculation of Bank Asset Thresholds Fed Accounts Figure Bank, NA Charter Application Fintech/Banking Relationships Fintech Regulatory Requirements Financial Data Sharing Safety Act First Blockchain Bank & Trust, N.A. Charter Application Flood Insurance Reauthorization GM Financial Bank Deposit Insurance Application Industrial Loan Corporation Loophole Reforms/ Square (ILC) and Rakuten Deposit Insurance Applications Interest Rate Caps Minority Depository Institutions Issues Mortgage Servicer Liquidity Facility Nomination of Isabel Guzman to serve as the Administrator of the U.S. Small Business Administration (SBA) Nomination of Dr. Janet Yellen to serve as Secretary of the Treasury OCC Interpretive Letter 1176/Protego & Anchorage Conversion Applications OCC Proposed Payments Charter Postal Banking Regulatory Burden Relief for Community Banks Regulatory and Tax Relief for Community Banks SBA 7(a) Loan Program Funding and Terms Troubled Debt Restructuring

Client expense: $910,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA), Treasury, Dept of