CDFI Bond Guarantee Program Improvement Act of 2022

S. 3441/H.R. 7733 CDFI Bond Guarantee Improvement Act of 2022- This bill proposes changes to the CDFI Fund Bond Guarantee Program.

Client expense: $10,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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.

Extending and modifying the CDFI Bond Guarantee Program. Worked to advance the CDFI Bond Guarantee Program Improvement Act of 2022 (S.3441 and H.R.7733) and passed the House as part of the Financial Services Racial Equity, Inclusion, and Economic Justice Act (H.R.2543) on June 15, 2022.

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to Federal Credit Union Charter Modernization Issues related to credit union operations Issues related to credit union field of membership Issues related to credit union service organization Issues related to NCUA's low income designation regulation Issues related to NCUA examination procedures Issues related to NCUA's regulation regarding liquidity Issues related to NCUA's rulemaking process Issues related to NCUA's regulatory review process Issues related to Federal Credit Union Bylaws Issues related to credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union By-Laws Issues related to credit unions' incidental powers Issues related to credit union service to marijuana businesses Issues related to material loss reports of the NCUA Office of Inspector General Issues related to the regulation of corporate credit unions Issues related to fixed assets Issues related to credit union conversions Issues related to credit union call report modernization Issues related to NCUA's Corporate Credit Union Stabilization Plan Issues related to NCUA's budget and the overhead transfer rate Issues related to Credit Union Service Organizations (CUSO) Issues related to the authority of the CFPB to exempt credit unions from its rulemaking Issues related to the CFPB rule to remittances and international wire transfers Issues related to CFPB's Leadership structure and Installing a Board rather than a Director Issues related to codifying the CFPB's Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to overdraft protection and check ordering practices Issues related to mortgage servicing Issues related to mortgage loan originator compensation and qualifications Issues related to the CFPB's rule regarding qualified mortgage / ability to repay Issues related to the CFPB's regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the CFPB's regulation on Truth-In-Lending Act / Real Estate Settlement Procedures Act Integrated Disclosures Issues related to the payday, vehicle title, and similar lending Issues related to short term lending products and advance deposit products Issues related to the CFPB's consumer complaint database Issues related to the CFPB's consumer complaint database Issues related to the Department of Justice's investigation entitled, "Operation Choke Point" Issues related to indirect auto lending Issues related to credit union service to unbanked and underbanked consumers Issues related to the Financial Accounting Standards Board (FASB) Issues related to data and cyber security Issues related to mobile banking and mobile payments Issues related to identity theft and fraud reduction Issues related to secure payments Issues related to merchant data breaches Issues related to the payments system and innovation Issues related to the Fed's implementation of same-day ACH Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements Issues related to the oversight of the Federal Housing Administration Issues related to the USDA Rural Development Loan Program Issues related to the Federal Home Loan Bank System Issues related to membership eligibility in the Federal Home Loan Bank System Issues related to financial literacy Issues related to Housing Finance Reform Issues related to student lending Issues related to the Economic Growth and Regulatory Paperwork Reduction Act Process Issues related to retirement security Issues related to flood insurance Issues related to consumer's access to records Issues related to Interchange Fees Issues related to the Equal Credit Opportunity Act Issues related to the Fair Housing Act Issues related to the merger of credit unions Issues related to the Real Estate Settlement Procedures Act Issues related to Community Reinvestment Act Issues related to Regulation Z Issues related to Military Lending Act Issues related to Financial Technology Issues related to Small Business Lending Data Collection requirements Issues related to Involuntary liquidation of Federal Credit Unions and Claims Procedures Issues related to Web-Bases Quantitative Testing of Point of Sale / ATM Overdraft Disclosure Forms Issues related to residential appraisals Issues related to FHA appraisal certification Issues related to FHA and USDA Loan Modifications Issues related to Faster Payments Issues related to the Fair Credit Reporting Act Issues related to cooperative funding sources in federal appropriations legislation Issues related to regulation of debt collection activity Issues related to capital reform for credit unions Issues related to diversity and inclusion in Financial Services Issues related to Section 124 of the Federal Credit Union Act Issues related to the Consumer Financial Protection Bureau's No-Action Letters and the BCFP Product Sandbox Issues related to enterprise validation and approval of credit score models Issues related to the availability of Funds and Collection of Checks (Regulation CC) Issues related to arbitration clauses Issues related to SBA 7(a) loan program Issues related to financial institutions operating on military installations Issues related to postal banking Issues related to Telephone Consumer Protection Act Issues related to financial technology (FINTECH) Issues related to robocalls and the draft Declatory Ruling (the ruling) and Third Further Notice of Proposted Rulemaking (FNPRM) CG Docket No 17-59, WC Docket No. 17 - 97 Issues related to payday and small dollar lending Issues related to leases of non-excess property on military bases Issues related to Opportunity Zones Issues related to minority homeownership Issues related to the ability of Federal Credit unions to establish their own fiscal year Issues related to a requirement that Federal credit unions file certain information regarding loan officers Issues related to enhancing flexibility of Federal Credit Unions to schedule board meetings Issues related to removing certain outdated responsibilites of Federal credit union board of directors Issues related to permitting Federal credit unions to expel disruptive members for just cause without a vote Issues related to permitting balloting for conversions from state to federal charter and from federal to state charter to be conducted electronically Issues related to PACE Loans Issues related to minority depository insitutions Issues related to AI and cloud computing Issues related to the Consumer Online Privacy Rights Act Issues related to COVID-19 crisis response legislation Issues related to the Paycheck Protection Program Issues related to Taxi Medallion loans Issues related to QRM Risk Retection Review Issues related to NCUA's proposed rule on combination transactions Issues related to the regulation of credit unions as employers Issues related to liability protections for businesses Issues related to remote notary Issues related to digital identity legislation Issues related Paid Leave Payroll Tax Credits Issues related to Economic Impact Payments Issues related to Fed Accounts Issues related to the Federal Reserve's Main Street Lending Program Issues related to troubled debt restructuring Issues related to Prompt Corective Action requirements Issues related to NCUA subordinated debt rulemaking Issues related to Uniform Residential Loan Application Issues related to digitalization of money Issues related to electronic signatures on wire transfer documents Issues related to cybercriminal activity during COVID-19 Issues related to lender forebearance Issues related to Paycheck Protection Program forgiveness process Issues related to Agriculture Lending Issues related to OCC payment charters Issues related to the Student Empowerment and Financial Literacy Act Issues related to OCC National Bank and Savings Association Digital Activities Issues related to the treatment of certain COVID-19 Loss Mitigation options under RESPA (Reg X) Issues related to premium assessments by the National Credit Union Share Insurance Issues related to the proposed exclusion of PPP Loans from financial institution asset calculations Issues related to Section 4013 of the CARES Act Issues related to Section 4016 of the CARES Act Issues related tot he oversight of prudential regulators Issues related to PAL 1 Program Issues related to credit union asset size thresholds for regulatory compliance Issues related to NCUA MERIT examination system Issues related to NCUA Derivatives rulemaking Issues related to mortgage servicer assistance Issues related to Section 4022 of the CARES Act Issues related to the ability of NCUA to offer forbearance from Prompt Corrective Action Requirements Issues related to Temporarily Excluding Certain Low-Risk Assets from the Credit Union Net Worth Ratio Issues related to London Inter-Bank Offered Rate (LIBOR) Issues related to the regulation of Federal Employment Laws Issues related to the Office of Comptroller Charter Issues related to the Crypto Charter Issues related to the Solar Winds Data Breach Issues related to PPP Loan Necessity Questionnaires Issues related to SBA Economic Injury Disaster Loan Advances Issues related to Seasoned QM Loan Definitions Issues related to FHFA Strategic Plan for 2021-2024 Issues related to GSE Housing Goals Issues related to Member Business Lending Issues related to interest rate caps Issues related to Federal Housing Finance Agency's (FHFA) recapitalization plans Issues related to rental and mortgage payment assistance Issues related to BSA / AML Regulation Issues related to CECL Accounting requirements Issues related to climate control issues and effect on financial institutions Issues related to UDAAP guidance and requirements Issues related to risk-based capital requirements Issues related to NCUA's Communications and Transparency Issues related to Enterprise liquidity framework (FHFA) Issues related to the discussion draft of the Expanding Financial Access for Underserved Communities Act Issues related to the NCUA's Capitalization of Interest in Connection with Loan Workouts and Modifications Rulemaking Issues related to the Federal Reserve's proposed Regulation II Issues related to Capitalizing interest on consumer loans Issues related to Cryptocurrency Issues related to proposed postal banking pilot program Issues related to proposed new tax reporting requirements for financial institutions Issues related to the implementation of consumer financial protection laws Issues related to the safety and soundness regulations of credit unions Issues related to investment authority Issues related to BSA / AML regulation and Cannabis Banking Issues related to rate cap legislation and the Military Lending Act Issues related to credit card interchange fees and routing Issues related to FY22 National Defense Authorization Act Issues related to NCUA Central Liquidity Facility Issues related to Climate and Natural disaster risk management at regulated entities Issues related to PSPA / QM Conflict Issues related to CAMELS proposal Issues related to credit union coverage under GNMA rules Issues related to Cryptocurrency and digital assets Issues related to the re-nomination of Todd Harper to the NCUA Board Issues related to examining frameworks to address future pandemic risk Issues related to the NDAA rate cap proposals Issues related to the collection of checks and other items by Federal Reserve Banks and Funds Transfers through Fedwire Issues related to the potential modifications to the Federal Reserve policy on payment system risk Issues related to Small Business Bankruptcy Issues related to mortgage-backed securities insurance Issues related to the state of the rural economy Issues related to financial barriers to minority and women-owned businesses' involvement in infrastructure projects Issues related to the President's working group on financial market's report on stablecoins Issues related to economic impact of growing burden of medical debt Issues related to the Credit Union Employee and Member Safety Act in the FY2022 Omnibus Appropriations Act Issues related to the Interagency Task Force on Property Appraisal and Valuation Equity (PAVE) appraisals Issues related to the National Defense Authorization Act FY2023 Issues related to the Administration of the CDFI Fund Issues related to Central Bank Digital Currency Issues related to National Flood Insurance Program Reauthorization Issues related to Reg. II, Dodd Frank, Durbin Amendment, Section 107531 Issues related to G20 Rome Leaders Declaration Issues related to the United States Innovation and Competition Act of 2021 Issues related to Prompt Corrective Action: Earnings Retention Waivers and Net Worth Restoration Plans Issues related to Prohibition on Inclusion of Adverse Information in Consumer Reporting in Cases of Human Trafficking Issues related to the Truth in Savings Act (TISA) and Part 707 of the NCUA Rules and Regulations Issues related to 40 Year Term Loan Modifications Issues related to data security and interchange fees Issues related to credit union loan maturity limits Issues related to credit union business lending caps Issues related to the administration of the CDFI Fund Issues related to the National Defense Authorization Act and Interchange fee issues Issues related to CDFI recertification applications Issues related to Protecting military service members and veterans from Financial scams and fraud Issues related to new consumer financial products and the impacts to workers Issues related to making the CFPB Accountable to Small Business Act Issues related to cyber incident notification requirements for Federally insured credit unions Issues related to ensuring responsible development of digital assets Issues related to the CFPB ensuring data aggregation services market is Fair, transparent and competitive H.J. Res 35, providing for Congressional disapproval under Chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders" S.J. Res 15, a joint resolution providing for congressional disapproval under Chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders" H.R. 133, the Consolidated Appropriations Act (2020) H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1395, the Housing Financial Literacy Act of 2021 H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act 0f 2021 H.R. 1996, Secure and Fair Enforcement (SAFE) Banking Act of 2021 H.R. 2040, the Financial Reporting Threshold Modernization Act H.R. 2311, To amend the Federal Credit Union Act to modernize certain processes regarding expulsion of credit union members for cause, and for other purposes H.R. 2471, the Consolidated Appropriations Act of 2022 H.R. 2547, the Comprehensive Debt Collection Improvement Act H.R. 3684, Infrastructure Investment and Jobs Act, Sec. 90005, Extension of enterprise guarantee fees H.R. 3958, Central Liquidity Facility Enhancement Act H.R. 3962, SECURE Notarization Act of 2021 H.R. 4277, Overdraft protection legislation H.R. 4495, the Down payment Toward Equity Act of 2021 H.R. 4773, the Consumer Financial Protection Commission Act H.R. 4905, Promoting New and Diverse Depository Institutions Act H.R. 5189, Member Business Loan Expansion Act H.R. 5206, Tax Gap Reform and IRS Enforcement Act H.R. 5305, Extending Government Funding and Delivering Emergency Assistance Act H.R. 5451, Protecting Financial Privacy Act of 2021 H.R. 5912, the Close the ILC Loophole Act H.R. 6889, Credit Union Board Modernization Act H.R. 7003, Expanding Financial Access to Underserved Communities Act H.R. 7022, the Strengthening Cyber-Security for the Financial Sector Act H.R. 7733, the CDFI Bond Guarantee Program Improvement Act of 2022 H.R. 7900, SAFE Banking, amendment #983 by Representative Beatty (OH), Amendment #543 offered by Representatives Dean (PA), Armstrong (ND), Perlmutter (CO),Reschenthalter (PA) and Escobar (TX) H.R. 8152, American Data Privacy and Protection Act H.R. 8294, the Transportation, Housing and Urban development, Agriculture, Rural development, Energy and Water Development, Financial Services and General Government, Interior, Environment, Military Construction, and Veterans affairs Appropriations Act of Fiscal Year 2023 H.R. 8485, the Expanding Access to Credit through Consumer-Permissioned Data Act S. 254, A bill to establish a Homeowner Assistance Fund at the Department of the Treasury S. 337, Stop Senior Scams Act S. 762, A bill to provide the National Credit Union Administration Board flexibility to increase Federal credit union loan maturities, and for other purposes S. 910, SAFE Banking Act of 2021 S. 1368, American Housing and Economic Mobility Act of 2021 S. 1625, Securing and Enabling Commerce Using Remote and Electronic Notarization Act S. 1767, the Credit Union Employee and Member Safety Act of 2021 S. 2857, Protection Financial Privacy Act of 2021 S. 3715, E-SIGN Modernization Act of 2022 S. 3813, Veterans Member Business Loan Act S. 4325, Credit Union Board Modernization S. 4356, The Responsible Financial Innovation Act S. 4676, Credit Card Competition Act of 2022 S. 4698, Improving Cybersecurity of Credit Unions Act S. 4879, Expanding Financial Access for Underserved Communities Act S. Amendment 6174, National Defense Authorization Act, Report on Credit and Debit Card

Extending and modifying the CDFI Bond Guarantee Program. Worked to advance the CDFI Bond Guarantee Program Improvement Act of 2022 (S.3441 and H.R.7733). Also worked on CDFI Bond Guarantee provisions included in the Financial Services Racial Equity, Inclusion, and Economic Justice Act (H.R.2543) as passed by the House on June 15, 2022.

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 3441/H.R. 7733 CDFI Bond Guarantee Improvement Act of 2022- This bill proposes changes to the CDFI Fund Bond Guarantee Program.

Client expense: $20,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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.