Farm Credit Administration Independent Authority Act

H.R. 1996 SAFE Banking Act H.R. 2543 Federal Reserve Racial and Economic Equity Act, Credit Union Provisions & Community Bank Amendment H.R. 2561 Promoting Access to Capital in Underbanked Communities Act of 2021 H.R. 2617 Consolidated Appropriations Act, opposed amendments related to Credit Card Competition Act H.R. 4277 Overdraft Protection Act H.R. 4345 FY 2022 Financial Services and General Government Appropriation - Postal Banking Pilot Program H.R. 5886 Prohibit IRS Financial Surveillance Act H.R. 5912 Close ILC Loophole Act H.R. 6037 Prohibit SBA 7(a) Direct Lending H.R. 6054 Small Business Lending Disclosure Act H.R. 6732 Small LENDER Act H.R. 6814 Small Business Fair Debt Collection Practices Act H.R. 7003 Expanding Financial Access for Underserved Communities Act H.R. 7412 Transparency in CFPB Cost-Benefit Analysis Act H.R. 7768 Farm Credit Administration Independence Authority Act H.R. 7776 National Defense Authorization Act, master accounts and services database H.R. 7900 National Defense Authorization Act, opposed amendments related to Credit Card Competition Act H.R. 8152 American Data Privacy and Protection Act H.R. 8443 Making the CFPB Accountable Act H.R. 8833 The Making Communities Stronger Through the Community Reinvestment Act H.R. 8874 Credit Card Competition Act H.R. 8950 the Digital Commodities Consumer Protection Act of 2022 H.R. 9599 Consumer Information Notification Requirement Act S. 910 SAFE Banking Act S. 1684 Federal Home Loan Banks Mission Implementation Act S. 3056 Prohibit IRS Financial Surveillance Act S. 3715 E-Sign Modernization Act S. 3954 Ban CBDC S. 3970 Stablecoin Transparency Act S. 4004 Small LENDER Act S. 4356 Lummis-Gillibrand Responsible Financial Innovation Act S. 4522 Transparency in CFPB Cost-Benefit Analysis Act S. 4674 Credit Card Competition Act S. 4698 Improving Cybersecurity of Credit Unions Act S. 4831 No CBDC Act S. 5189 Close the Shadow Banking Loophole Act S. 5340 Stablecoin TRUST Act of 2022 S. 5341 A bill to amend the Federal Reserve Act to provide greater accountability to the Federal Reserve System Bank Merger Policy BankOn accounts Banking Services Fees Cannabis Banking CDFI Certification Central Bank Digital Currency Climate Risk Disclosure Requirements Climate-Related Financial Regulation Community Bank Access to Capital Community Banks on Military Bases Community Development Financial Institutions (CDFI) Fund Appropriations Community Reinvestment Act Consolidated Appropriations Act, supported inclusion of the SAFE Banking Act; opposed inclusion of Credit Card Competition Act Credit Reporting Credit Union Acquisitions of Community Banks Credit Union Business Lending Powers Credit Union Cybersecurity Requirements Credit Union Field of Membership Rules Credit Union Growth/Powers/Abusive Behavior Credit Union Supplemental Capital Cryptocurrency Customer Data Access, Implementation of Dodd Frank Act Section 1033 Cybersecurity Data Privacy Discussion Draft Data Security, Breaches and Privacy De Novo Bank Formation Dodd Frank Act 1071- Small Business Loan Data Collection Digital Assets Regulation Durbin Amendment on Interchange; Extension to Credit Cards FDIC Deposit Insurance Assessments FDIC Premium Increases FDIC Supervisory Appeals Review Committee and Policy FHFA Capital Rules Financial Data Privacy Discussion Draft Fintech Regulatory Requirements Fintech/Banking Relationships Flood Insurance Reauthorization Industrial Loan Corporation Loophole Reforms/ Rakuten (ILC) et al, Deposit Insurance Applications Interchange Minority Depository Institutions Issues National Defense Authorization Act, Report Language on Financial Institution leases on military bases National Defense Authorization Act, Supported Inclusion of the SAFE Banking Act; Opposed Inclusion of Credit Card Competition Act as an Amendment Overdraft Fees Overdraft Protection P2P Payment Applications Fraud Postal Banking SAFE Banking Act, support for inclusion in America COMPETES Act Conference SBA 7(a) Loan Program Funding and Terms SBA Direct 7(a) Direct Lending Secure Notarization Small Business Loan Data Collection--CFPB Implementation of Dodd-Frank Act Section 1071 Stablecoins Stablecoin Innovation and Protection Act of 2022 (draft) Stablecoin Legislation - Waters-McHenry Discussion Draft Stablecoin TRUST Act (draft)

Client expense: $1,303,790 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of

H.R. 1977 Enhancing Credit Opportunities for Rural America Act (ECORA) H.R. 7768 Farm Credit Administration Independence Authority Act H.R. 8950 Digital Commodities Consumer Protection Act of 2022 S. 2202 Enhancing Credit Opportunities for Rural America (ECORA) S. 4760 - Digital Commodities Consumer Protection Act of 2022 Digital assets FCS Cyber Security - Favor Transparency & FCS following Bank like regulations Section 1071 & Farm Credit System compliance USDA Guaranteed Loan Programs regarding Beginning Farmer and Rancher (BFR) Enhancements

Client expense: $1,303,790 · Firm income: Not reported

H.R. 6037 Prohibit SBA 7(a) Direct Lending H.R. 6307 Protecting Access to Credit for Small Business Act H.R. 7768 Farm Credit Administration Independence Authority Act S. 3382 Protecting Access to Credit for Small Business Act PPP Forgiveness Process SBA 7(a) Program Funding and Terms SBA COVID-19 Lending Programs SBA Direct Lending

Client expense: $718,825 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 1977 Enhancing Credit Opportunities for Rural America Act (ECORA) H.R. 7768 Farm Credit Administration Independence Authority Act H.R. 8950 Digital Commodities Consumer Protection Act of 2022 S. 2202 Enhancing Credit Opportunities for Rural America (ECORA) S. 4760 - Digital Commodities Consumer Protection Act of 2022 Digital assets Farm Credit Administration - Favor updating Young, Beginning, Farmer requirements FCS Cyber Security - Favor Transparency & FCS following Bank like regulations Letter to CFPB Urging restrictions of credit union purchases or banks; facilitate community banks purchasing local community bank instead of allowing large banks to purchase local banks Letter to UDSDA with recommendations on Livestock Dealer Trust regulations Section 1071 & Farm Credit System compliance USDA Guaranteed Loan Programs regarding Beginning Farmer and Rancher (BFR) Enhancements

Client expense: $718,825 · Firm income: Not reported

H.R. 1996 SAFE Banking Act H.R. 2543 Federal Reserve Racial and Economic Equity Act, Credit Union Provisions & Community Bank Amendment Amendment #6 to H.R. 2543, to repeal Section 1071 of the Dodd-Frank Act Sec. 521, 522, 523 & 524 of H.R.2543 - Federal Reserve Racial and Economic Equity Act H.R. 2561 Promoting Access to Capital in Underbanked Communities Act of 2021 H.R. 3009 Improving Language Access in Mortgage Servicing H.R. 4277 Overdraft Protection Act H.R. 4345 FY 2022 Financial Services and General Government Appropriation - Postal Banking Pilot Program H.R. 4590 Promoting New and Diverse Depository Institutions Act H.R. 5376 Inflation Reduction Act of 2022 (Build Back Better) H.R. 5886 Prohibit IRS Financial Surveillance Act H.R. 5912 Close ILC Loophole Act H.R. 6037 Prohibit SBA 7(a) Direct Lending H.R. 6054 Small Business Lending Disclosure Act H.R. 6732 Small LENDER Act H.R. 6739 Business Loan Privacy Act H.R. 6802 Prevent Racial Profiling in Lending Act H.R. 6814 Small Business Fair Debt Collection Practices Act H.R. 6889 The Credit Union Board Modernization Act H.R. 7003 Expanding Financial Access for Underserved Communities Act H.R. 7412 Transparency in CFPB Cost-Benefit Analysis Act H.R. 7768 Farm Credit Administration Independence Authority Act H.R. 8152 American Data Privacy and Protection Act H.R. 8443 Making the CFPB Accountable Act H.R. 8833 The Making Communities Stronger Through the Community Reinvestment Act H.R. 8874 Credit Card Competition Act H.R. 8950 the Digital Commodities Consumer Protection Act of 2022 S. 910 SAFE Banking Act S. 1684 Federal Home Loan Banks Mission Implementation Act S. 3056 Prohibit IRS Financial Surveillance Act S. 3382 Protecting Access to Credit for Small Businesses Act S. 3715 E-Sign Modernization Act S. 3954 Ban CBDC S. 4004 Small LENDER Act S. 4356 Lummis-Gillibrand Responsible Financial Innovation Act S. 4522 Transparency in CFPB Cost-Benefit Analysis Act S. 4674 Credit Card Competition Act S. 4831 No CBDC Act Amendments 69 and 70 to FY2023 FSGG Appropriations Bill (Postal banking) Bank Merger Policy BankOn accounts Banking Services Fees Cannabis Banking Central Bank Digital Currency Climate Risk Disclosure Requirements Climate-Related Financial Regulation Community Bank Access to Capital Community Banks on Military Bases Community Development Financial Institutions (CDFI) Fund Appropriations Community Reinvestment Act Consumer Financial Protection Bureau, report of financial services in rural America Credit Reporting Credit Union Acquisitions of Community Banks Credit Union Business Lending Powers Credit Union Cybersecurity Requirements Credit Union Field of Membership Rules Credit Union Growth/Powers/Abusive Behavior Credit Union Supplemental Capital Cryptocurrency Customer Data Access, Implementation of Dodd Frank Act Section 1033 Cybersecurity Data Privacy Discussion Draft Data Security, Breaches and Privacy De Novo Bank Formation Dodd Frank Act 1071- Small Business Loan Data Collection Digital Assets Regulation Durbin Amendment on Interchange; Extension to Credit Cards FDIC Deposit Insurance Assessments FDIC Premium Increases FDIC Supervisory Appeals Review Committee and Policy Financial Data Privacy Discussion Draft Fintech Regulatory Requirements Fintech/Banking Relationships Flood Insurance Reauthorization Industrial Loan Corporation Loophole Reforms/ Rakuten (ILC) et al, Deposit Insurance Applications Interchange Interest Rate Caps Minority Depository Institutions Issues National Defense Authorization Act, Opposition to Inclusion of Credit Card Competition Act as an Amendment National Defense Authorization Act, Report Language on Financial Institution leases on military bases OCC Proposed Payments Charter Overdraft Fees Overdraft Protection P2P Payment Applications Fraud Postal Banking Protecting Consumers from Payment Scams Act (draft) SAFE Banking Act, support for inclusion in America COMPETES Act Conference SBA 7(a) Loan Program Funding and Terms SBA Direct 7(a) Direct Lending Secure Notarization Small Business Loan Data Collection--CFPB Implementation of Dodd-Frank Act Section 1071 Stablecoins Stablecoin Innovation and Protection Act of 2022 (draft) Stablecoin Legislation - Waters-McHenry Discussion Draft Stablecoin TRUST Act (draft) Unfair, deceptive, or abusive acts and practices (UDAAP)

H.R.7768 - Farm Credit Administration Independent Authority Act

Client expense: $330,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Expanded forgiveness of Paycheck Protection Program (PPP) loans Implementation of Sect. 1071 of Dodd-Frank Act, data collection on small business lending H.R.7768 -the Farm Credit Administration Independent Authority Act, a bill applying commercial lending protections to small business lending and extend the CFPB's regulatory authority to include small business financing H.R.6054 -the Small Business Lending Disclosure Act of 2021, a bill applying commercial lending protections to small business lending and extend the CFPB's regulatory authority to include small business financing

Client expense: $70,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), HOUSE OF REPRESENTATIVES, SENATE, Small Business Administration (SBA), Treasury, Dept of

Carbon Credit Markets S. 1251, H.R. 2820 - Growing Climate Solutions Act H.R. 2518 - Precise Act Precision Agriculture Financing Legislation Biofuels Policy - Minimum Octane Standard S. 2750 Precision Agriculture Loan Program Act H.R. 6390 Electric Vehicle Charging Infrastructure for Farmers Act H.R. 7768 Farm Credit Administration Independent Authority Act Agriculture Data Privacy Legislation

Client expense: $270,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), HOUSE OF REPRESENTATIVES, SENATE

Carbon Credit Markets S. 1251, H.R. 2820 - Growing Climate Solutions Act H.R. 2518 - Precise Act Precision Agriculture Financing Legislation Biofuels Policy - Minimum Octane Standard S. 2750 Precision Agriculture Loan Program Act H.R. 6390 Electric Vehicle Charging Infrastructure for Farmers Act H.R. 7768 Farm Credit Administration Independent Authority Act Agriculture Data Privacy Legislation

Client expense: $270,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), HOUSE OF REPRESENTATIVES, SENATE

H.R. 1996 SAFE Banking Act H.R. 2543 Federal Reserve Racial and Economic Equity Act, Credit Union Provisions & Community Bank Amendment Amendment #6 to H.R. 2543, to repeal Section 1071 of the Dodd-Frank Act Sec. 521, 522, 523 & 524 of H.R.2543 - Federal Reserve Racial and Economic Equity Act H.R. 2561 Promoting Access to Capital in Underbanked Communities Act of 2021 H.R. 3009 Improving Language Access in Mortgage Servicing H.R. 4277 Overdraft Protection Act H.R. 4345 FY 2022 Financial Services and General Government Appropriation - Postal Banking Pilot Program H.R. 5376 The Build Back Better Act H.R. 5886 Prohibit IRS Financial Surveillance Act H.R. 5912 Close ILC Loophole Act H.R. 6037 Prohibit SBA 7(a) Direct Lending H.R. 6054 Small Business Lending Disclosure Act H.R. 6307 Protecting Access to Credit for Small Businesses Act H.R. 6732 Small LENDER Act H.R. 6739 Business Loan Privacy Act H.R. 6745 Ensuring Diversity in Community Banking Act H.R. 6802 Prevent Racial Profiling in Lending Act H.R. 6814 Small Business Fair Debt Collection Practices Act H.R. 7003 Expanding Financial Access for Underserved Communities Act H.R. 7022 Strengthening Cybersecurity Act H.R. 7412 Transparency in CFPB Cost-Benefit Analysis Act H.R. 7768 Farm Credit Administration Independence Authority Act H.R. 8152 American Data Privacy and Protection Act S. 910 SAFE Banking Act S. 1684 Federal Home Loan Banks Mission Implementation Act S. 3056 Prohibit IRS Financial Surveillance Act S. 3382 Protecting Access to Credit for Small Businesses Act S. 3409 A bill to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024, and for other purposes. S. 3441 CDFI Bond Guarantee Program Improvement Act S. 3715 E-Sign Modernization Act S. 3745 TAILOR Act S. 3954 Ban CBDC S. 4004 Small LENDER Act S. 4356 Lummis-Gillibrand Responsible Financial Innovation Act Bank Merger Policy Bank Secrecy Act/Anti-Money Laundering Rules/Legislation, including Beneficial Ownership Issue Banking Services Fees Cannabis Banking Central Bank Digital Currency Climate Risk Disclosure Requirements Climate-Related Financial Regulation Community Bank Access to Capital Community Development Financial Institutions (CDFI) Fund Appropriations Community Reinvestment Act Consumer Financial Protection Bureau, report of financial services in rural America Credit Reporting Credit Union Acquisitions of Community Banks Credit Union Business Lending Powers Credit Union Cybersecurity Requirements Credit Union Field of Membership Rules Credit Union Growth/Powers/Abusive Behavior Credit Union Supplemental Capital Cryptocurrency Customer Data Access, Implementation of Dodd Frank Act Section 1033 Cybersecurity Data Security, Breaches and Privacy De Novo Bank Formation Dodd Frank Act 1071- Small Business Loan Data Collection Digital Assets Regulation Durbin Amendment on Interchange; Extension to Credit Cards Emergency Capital Investment Program Expanding Opportunity for Minority Depository Institutions Act (draft) Faster/Instant Payments FDIC Premium Increases FDIC Supervisory Appeals Review Committee and Policy Federal Reserve Accounts for Consumers Financial Data Privacy Discussion Draft Financial Inclusion Fintech Regulatory Requirements Fintech/Banking Relationships Flood Insurance Reauthorization Industrial Loan Corporation Loophole Reforms/ Rakuten (ILC) et al, Deposit Insurance Applications Interchange Interest Rate Caps IRS Reporting of Financial Account Inflows/Outflows Minority Depository Institutions Issues OCC Proposed Payments Charter Overdraft Fees Overdraft Protection Patent Reform Legislation Postal Banking Protecting Consumers from Payment Scams Act (draft) SAFE Banking Act, support for inclusion in America COMPETES Act Conference SBA 7(a) Loan Program Funding and Terms SBA Direct 7(a) Direct Lending Secure Notarization Small Business Loan Data Collection--CFPB Implementation of Dodd-Frank Act Section 1071 Stablecoins Stablecoin Innovation and Protection Act of 2022 (draft) Stablecoin TRUST Act (draft) H.R. 4590 - Promoting New and Diverse Depository Institutions Act H. R. 5376 - Inflation Reduction Act of 2022 (Build Back Better) H.R. 6889 - The Credit Union Board Modernization Act H.R. 8443, Making the CFPB Accountable Act H.R. 8833, the Making Communities Stronger Through the Community Reinvestment Act H.R. 8874, Credit Card Competition Act H.R. 8950, the Digital Commodities Consumer Protection Act of 2022 S. 4522 - Transparency in CFPB Cost-Benefit Analysis Act S. 4674, Credit Card Competition Act S. 4831 No CBDC Act Amendments 69 and 70 to FY2023 FSGG Appropriations Bill (Postal banking) BankOn accounts Community Banks on Military Bases FDIC Deposit Insurance Assessments National Defense Authorization Act, opposition to inclusion of Credit Card Competition Act as an Amendment National Defense Authorization Act, report language on financial institution leases on military bases P2P Payment Applications Fraud Stablecoin Legislation - Waters-McHenry Discussion Draft Unfair, deceptive, or abusive acts and practices (UDAAP)

H.R. 1977 Enhancing Credit Opportunities for Rural America Act (ECORA) H.R. 7768 Farm Credit Administration Independence Authority Act S. 2202 Enhancing Credit Opportunities for Rural America (ECORA) USDA Guaranteed Loan Programs regarding Beginning Farmer and Rancher (BFR) Enhancements

Client expense: $718,825 · Firm income: Not reported

H.R. 6037 Prohibit SBA 7(a) Direct Lending H.R. 6307 Protecting Access to Credit for Small Business Act H.R. 7768 Farm Credit Administration Independence Authority Act S. 3382 Protecting Access to Credit for Small Business Act CARES Act, Paycheck Protection Program (PPP) Implementation PPP Forgiveness Process PPP Modifications to Program SBA 7(a) Program Funding and Terms SBA COVID-19 Lending Programs SBA Direct Lending

Client expense: $718,825 · Firm income: Not reported

Carbon Credit Markets S. 1251, H.R. 2820 - Growing Climate Solutions Act H.R. 2518 - Precise Act Precision Agriculture Financing Legislation Biofuels Policy - Minimum Octane Standard S. 2750 Precision Agriculture Loan Program Act H.R. 6390 Electric Vehicle Charging Infrastructure for Farmers Act H.R. 7768 Farm Credit Administration Independent Authority Act

Client expense: $175,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), HOUSE OF REPRESENTATIVES, SENATE

H.R.7768 - Farm Credit Administration Independent Authority Act

Client expense: $140,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 1977 Enhancing Credit Opportunities for Rural America Act (ECORA) H.R. 7768 Farm Credit Administration Independence Authority Act S. 2202 Enhancing Credit Opportunities for Rural America (ECORA) USDA Guaranteed Loan Programs regarding Beginning Farmer and Rancher (BFR) Enhancements

Client expense: $1,840,000 · Firm income: Not reported

H.R. 1996 SAFE Banking Act H.R. 2543 Federal Reserve Racial and Economic Equity Act, Credit Union Provisions & Community Bank Amendment Amendment #6 to H.R. 2543, to repeal Section 1071 of the Dodd-Frank Act Sec. 521, 522, 523 & 524 of H.R.2543 - Federal Reserve Racial and Economic Equity Act H.R. 2561 Promoting Access to Capital in Underbanked Communities Act of 2021 H.R. 3009 Improving Language Access in Mortgage Servicing H.R. 4277 Overdraft Protection Act H.R. 4345 FY 2022 Financial Services and General Government Appropriation - Postal Banking Pilot Program H.R. 5376 The Build Back Better Act H.R. 5886 Prohibit IRS Financial Surveillance Act H.R. 5912 Close ILC Loophole Act H.R. 6037 Prohibit SBA 7(a) Direct Lending H.R. 6054 Small Business Lending Disclosure Act H.R. 6307 Protecting Access to Credit for Small Businesses Act H.R. 6732 Small LENDER Act H.R. 6739 Business Loan Privacy Act H.R. 6745 Ensuring Diversity in Community Banking Act H.R. 6802 Prevent Racial Profiling in Lending Act H.R. 6814 Small Business Fair Debt Collection Practices Act H.R. 7003 Expanding Financial Access for Underserved Communities Act H.R. 7022 Strengthening Cybersecurity Act H.R. 7412 Transparency in CFPB Cost-Benefit Analysis Act H.R. 7768 Farm Credit Administration Independence Authority Act H.R. 8152 American Data Privacy and Protection Act S. 910 SAFE Banking Act S. 1684 Federal Home Loan Banks Mission Implementation Act S. 3056 Prohibit IRS Financial Surveillance Act S. 3382 Protecting Access to Credit for Small Businesses Act S. 3409 A bill to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024, and for other purposes. S. 3441 CDFI Bond Guarantee Program Improvement Act S. 3715 E-Sign Modernization Act S. 3745 TAILOR Act S. 3954 Ban CBDC S. 4004 Small LENDER Act S. 4356 Lummis-Gillibrand Responsible Financial Innovation Act Bank Merger Policy Bank Secrecy Act/Anti-Money Laundering Rules/Legislation, including Beneficial Ownership Issue Banking Services Fees Cannabis Banking Central Bank Digital Currency Climate Risk Disclosure Requirements Climate-Related Financial Regulation Community Bank Access to Capital Community Development Financial Institutions (CDFI) Fund Appropriations Community Reinvestment Act Consumer Financial Protection Bureau, report of financial services in rural America Credit Reporting Credit Union Acquisitions of Community Banks Credit Union Business Lending Powers Credit Union Cybersecurity Requirements Credit Union Field of Membership Rules Credit Union Growth/Powers/Abusive Behavior Credit Union Supplemental Capital Cryptocurrency Customer Data Access, Implementation of Dodd Frank Act Section 1033 Cybersecurity Data Security, Breaches and Privacy De Novo Bank Formation Dodd Frank Act 1071- Small Business Loan Data Collection Digital Assets Regulation Durbin Amendment on Interchange; Extension to Credit Cards Emergency Capital Investment Program Expanding Opportunity for Minority Depository Institutions Act (draft) Faster/Instant Payments FDIC Premium Increases FDIC Supervisory Appeals Review Committee and Policy Federal Reserve Accounts for Consumers Financial Data Privacy Discussion Draft Financial Inclusion Fintech Regulatory Requirements Fintech/Banking Relationships Flood Insurance Reauthorization Industrial Loan Corporation Loophole Reforms/ Rakuten (ILC) et al, Deposit Insurance Applications Interchange Interest Rate Caps IRS Reporting of Financial Account Inflows/Outflows Minority Depository Institutions Issues OCC Proposed Payments Charter Overdraft Fees Overdraft Protection Patent Reform Legislation Postal Banking Protecting Consumers from Payment Scams Act (draft) SAFE Banking Act, support for inclusion in America COMPETES Act Conference SBA 7(a) Loan Program Funding and Terms SBA Direct 7(a) Direct Lending Secure Notarization Small Business Loan Data Collection--CFPB Implementation of Dodd-Frank Act Section 1071 Stablecoins Stablecoin Innovation and Protection Act of 2022 (draft) Stablecoin TRUST Act (draft)

H.R. 6037 Prohibit SBA 7(a) Direct Lending H.R. 6307 Protecting Access to Credit for Small Business Act H.R. 7768 Farm Credit Administration Independence Authority Act S. 3382 Protecting Access to Credit for Small Business Act CARES Act, Paycheck Protection Program (PPP) Implementation PPP Forgiveness Process PPP Modifications to Program SBA 7(a) Program Funding and Terms SBA COVID-19 Lending Programs SBA Direct Lending

Client expense: $1,840,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Small Business Administration (SBA)

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Community Bank Positions on New and Emerging Issues - Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. SBA Direct Lending (Congress) Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements fall disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Climate Risks (Administration, Congress, and the Agencies) CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporating material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House) Legislation and Regulation - H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) H.R. 7768 - Farm Credit Administration Independence Authority Act (all sections) which is legislation to exempt the Farm Credit System from being regulated by the CFPB and from compliance with Section 1071 of the Dodd-Frank Act - small business data collection (House) H.R. 2543 - Federal Reserve Racial and Economic Equity Act - Amendment to include H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) Letters - None Action Alerts - Action Alert regarding: Expanded Credit Union Powers / H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) Miscellaneous - None

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve, and must be closed. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Community Bank Positions on New and Emerging Issues - Leadership for Bank Regulatory Agencies (Administration, Congress, and the Agencies) Recent nominees have held extreme views on the banking system and financial services and their nominations have increasingly caused unproductive political wrangling. Nominees should be qualified, hold reasonable positions, be willing to work collegially and cooperatively with colleagues and counterparts, serve the best interests of the banking and financial system and economy, and clearly understand the vital importance of and support community banks. Fintechs and Innovation in Financial Services (Congress and the Agencies) Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Special Purpose National Banks (SPNBs) (OCC) SPNBs, raise many concerns. They cannot have the advantages of a bank charter with limited requirements, regulations, and liability. Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. SBA Direct Lending (Congress) Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Financial Inclusion (Congress and the Agencies) CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking (Congress) Public banking (i.e., publicly-owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Current Expected Credit Loss Model (CECL) (FASB and the Agencies) Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements fall disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Nonsufficient Funds (Overdraft) Policies and Practices (OCC and the CFPB) CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include including returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Climate Risks (Administration, Congress, and the Agencies) CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporating material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. Bank Merger Activity (Congress and the Agencies) New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and FDIC) Legislation and Regulation - H.R. 5912 - Close the ILC Loophole Act (all sections) which is legislation to reform the regulation of industrial loan companies (ILCs) and their parent companies to provide for consolidated federal supervision (House) H.R. 4421 - America COMPETES Act of 2022 (in conference committee/reconciliation) H.R. 1996 - The SAFE Banking Act which permits the banking of cannabis related businesses in states where it is legal (House and Senate) H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) H.R. 7768 - Farm Credit Administration Independence Authority Act (all sections) which is legislation to exempt the Farm Credit System from being regulated by the CFPB and from compliance with Section 1071 of the Dodd-Frank Act - small business data collection (House) H.R. 2543 - Federal Reserve Racial and Economic Equity Act - Amendment to include H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) Letters - Comment Letter to the Federal Reserve System regarding: Supplemental Notice and request for Comments, Guidelines for Evaluating Account and Service Requests - Docket No. OP-1747 (Federal Reserve) Comment Letter to the FDIC regarding: Statement of Principles for Climate-Related Financial Risk Management for Large Financial Institutions - RIN 3064-ZA32 (FDIC) Comment Letter to the Federal Reserve regarding: Money and Payments: The Digital Dollar in the Age of Digital Transformation (Federal Reserve) Comment Letter to the FDIC regarding: Guidelines for Appeals of Material Supervisory Determinations - RIN 3064-ZA20 (FDIC) Action Alerts - Action Alert regarding: Expanded Credit Union Powers / H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) Miscellaneous - Comment Letter to the CFPB about Fees Imposed by Providers of Financial Products or Services (FDIC and House) Application to CFPBs regulatory sandbox (CFPB) Comment Letter to the Federal Reserve about Money and Payments: The Digital Dollar in the Age of Digital Transformation (House)

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve, and must be closed. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Community Bank Positions on New and Emerging Issues - Leadership for Bank Regulatory Agencies (Administration, Congress, and the Agencies) Recent nominees have held extreme views on the banking system and financial services and their nominations have increasingly caused unproductive political wrangling. Nominees should be qualified, hold reasonable positions, be willing to work collegially and cooperatively with colleagues and counterparts, serve the best interests of the banking and financial system and economy, and clearly understand the vital importance of and support community banks. Fintechs and Innovation in Financial Services (Congress and the Agencies) Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Special Purpose National Banks (SPNBs) (OCC) SPNBs, raise many concerns. They cannot have the advantages of a bank charter with limited requirements, regulations, and liability. Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. SBA Direct Lending (Congress) Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Financial Inclusion (Congress and the Agencies) CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking (Congress) Public banking (i.e., publicly-owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Current Expected Credit Loss Model (CECL) (FASB and the Agencies) Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements fall disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Nonsufficient Funds (Overdraft) Policies and Practices (OCC and the CFPB) CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include including returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Climate Risks (Administration, Congress, and the Agencies) CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporating material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. Bank Merger Activity (Congress and the Agencies) New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and FDIC) Legislation and Regulation - H.R. 5912 - Close the ILC Loophole Act (all sections) which is legislation to reform the regulation of industrial loan companies (ILCs) and their parent companies to provide for consolidated federal supervision (House) H.R. 4421 - America COMPETES Act of 2022 (in conference committee/reconciliation) H.R. 1996 - The SAFE Banking Act which permits the banking of cannabis related businesses in states where it is legal (House and Senate) H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) H.R. 7768 - Farm Credit Administration Independence Authority Act (all sections) which is legislation to exempt the Farm Credit System from being regulated by the CFPB and from compliance with Section 1071 of the Dodd-Frank Act - small business data collection (House) H.R. 2543 - Federal Reserve Racial and Economic Equity Act - Amendment to include H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) Letters - Comment Letter to the Federal Reserve System regarding: Supplemental Notice and request for Comments, Guidelines for Evaluating Account and Service Requests - Docket No. OP-1747 (Federal Reserve) Comment Letter to the FDIC regarding: Statement of Principles for Climate-Related Financial Risk Management for Large Financial Institutions - RIN 3064-ZA32 (FDIC) Comment Letter to the Federal Reserve regarding: Money and Payments: The Digital Dollar in the Age of Digital Transformation (Federal Reserve) Comment Letter to the FDIC regarding: Guidelines for Appeals of Material Supervisory Determinations - RIN 3064-ZA20 (FDIC) Action Alerts - Action Alert regarding: Expanded Credit Union Powers / H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) Miscellaneous - Comment Letter to the CFPB about Fees Imposed by Providers of Financial Products or Services (FDIC and House) Application to CFPBs regulatory sandbox (CFPB) Comment Letter to the Federal Reserve about Money and Payments: The Digital Dollar in the Age of Digital Transformation (House)

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Community Bank Positions on New and Emerging Issues - Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements fall disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Climate Risks (Administration, Congress, and the Agencies) CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporating material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House) Legislation and Regulation - H.R. 7768 - Farm Credit Administration Independence Authority Act (all sections) which is legislation to exempt the Farm Credit System from being regulated by the CFPB and from compliance with Section 1071 of the Dodd-Frank Act - small business data collection (House) Letters - None Action Alerts - None Miscellaneous - None