Building Credit Access for Veterans Act of 2023

Protect the credit union tax exemption; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their nearly 140 million members; Support regulatory relief for credit unions; Provide guidance or rulemakings rather than rule through enforcement; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; Support increase in funding for CDFI Fund, MDIs, and the CDRLF; Support extending GLBA-like data security measures to retailers and fintechs; Support recognizing GLBA compliance in any privacy legislation; Oppose private right of action in data privacy legislation; Support NCUA as credit unions sole data privacy regulator; Oppose opt-in requirement for use of non-public personal information in data privacy legislation; Support federal preemption of state data privacy laws; Oppose NCUA examination authority for 3rd party vendors; Oppose NCUA adopting a dedicated consumer compliance examination; Support extended NCUA examination cycle; Support NCUA Central Liquidity Facility (CLF) improvements; Support vendor information sharing among financial regulators; Support NCUA independence as regulator and insurer; Oppose unsustainable NCUA budget growth; Support increased NCUA assistance for MDI credit unions; Support adjusting Dodd-Frank Act thresholds for inflation; Support legislative action to limit Regulation E liability; Support fair distribution of Regulation E error resolution responsibilities; Support greater investment authorities for credit unions; Support expansion of Low-Income Housing Tax Credit; Support publication of list of entities with access to Federal Reserve Bank accounts and services; Support legislative action to clarify CFPBs UDAAP authority; Support parity in credit union and bank federal deposit insurance levels; Oppose increased NCUA authority to charge share insurance premiums; Oppose SBA direct lending authority; Oppose fintech participation in SBA lending programs; Prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; Support increased CFPB transparency in rulemaking, supervision, and enforcement; Support CFPB coordination with NCUA in policymaking; Support CFPB basing policy on thorough research and data analysis; CFPB should engage in interagency coordination on Section 1033 consumer access to financial records rulemaking; Oppose CFPBs characterization of regulated and disclosed financial services fees as junk fees; CFPB should explore streamlining required fee disclosures; Oppose mandatory grace period for credit card late payments; CFPB should clarify UDAAP authority; CFPB should respect GLBAs data security regulatory structure; CFPB should limit impact and burden from final rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); Support prohibiting CFPB expending funds to implement the Section 1071 Small Business Lending Data Collection final rule (RIN: 3170-AA09); Improve examination coordination between CFPB and NCUA; Support CFPB exercise of larger participant authority to oversee fintech companies; Support clear regulatory framework for digital assets to encourage responsible innovation and permit credit union participation; Support CDFI Fund transparency on certification changes; Oppose changes to CDFI Fund certification process; Support Congressional oversight of SBAs Affiliation and Small Business Lending Company final rules; Support legislation to limit impact of SBAs Affiliation and Small Business Lending Company final rules; Support tax deduction for mortgage insurance premiums; Support modification or removal of the credit union member business lending cap; Support increasing credit union loan maturity limits; Support allowing credit unions to add underserved areas to their FOM; Support removing service area requirement for FOM expansion; Support increasing the credit union interest rate ceiling; Oppose national all-in interest rate cap; Oppose expanding the Fair Debt Collection Practices Act to cover business loans; Support credit union Community Reinvestment Act exemption; Support regulator-approved credit union mergers; Support regulations adhering to intent of the Fair Credit Reporting Act; Support regulation of credit reporting agencies and credit repair organizations; Oppose legislation granting for-profit banks nominal leases on military installations; Support credit union access to nominal leases on military installations; Support alternative credit scoring models; Oppose exclusion of accurate information from credit reports; Support FinCEN funding; Support FinCEN oversight; Support increasing SAR and CTR thresholds; Support disbursal of ECIP funding; Oppose NCUA acting as a climate regulator; Support credit union eligibility for the Greenhouse Gas Reduction Fund; Support Congressional oversight of the Federal Reserve Overnight Reverse Repo Facility; FCC should tailor robocall and robotext regulations to allow credit unions to serve their members; Support placing CFPB under regular appropriations process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs and consider wealth-building home loan pilot programs; Oppose increase in FHFA guarantee fees; Support elimination of guarantee fees for credit union mortgages; Support regulation of fintechs in mortgage lending; Support alternative credit scoring models; Oppose development of a CBDC; Support prevention of an NFIP lapse; Support improving veterans access to capital by exempting credit unions business loans to veterans from the credit union member business lending cap; Support expanding the definition of Community Financial Institutions (CFIs) in the Federal Home Loan Bank Act (FHLB Act) to include credit unions and Treasury-certified non-depository community development financial institutions; Support government guarantees to stabilize mortgage-backed securities market; Support pilot programs for wealth-building home loans and zero-down mortgages; Support quality- rather than quantity-based GSE loan pricing; Oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; Support parity for credit unions related to stablecoin regulation; Treasury should address the demand for coins to help consumers who rely on cash transactions; Support addressing appraisal bias and modernize the appraisal process for consistency; Support easing requirements for de novo credit unions; Support providing flexibility for credit unions to issue subordinated debt; Support improvements to ease the process for forgiveness of PPP loans to small businesses; Oppose limits on fee income for credit unions including courtesy pay; Support limiting burdens of HMDA rule on credit unions; CFPB should remove unnecessary and unused data points related to HMDA reporting; Support permanently increasing reporting thresholds for open- and closed-end loans; Support permanent adoption of CFPBs expired temporary relief of E-SIGN regulation; Oppose Federal Reserve proposal to decrease debit interchange fee cap (Docket No. R‐1818); Support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support Credit Union Board Modernization Act (H.R. 582; S. 610); Support Promoting Access to Capital in Underbanked Communities Act (H.R. 758); Support Promoting New and Diverse Depository Institutions Act (H.R. 1533; S. 2252); Support Consumer Financial Protection Commission Act (H.R. 1410); Support SECURE Notarization Act (H.R. 1059; S. 1212); Support Prohibiting IRS Financial Surveillance Act (H.R. 1010; S. 453); Support CBDC Anti-Surveillance State Act (H.R. 1122; H.R. 5403); Support Data Privacy Act (H.R. 1165); Support Veterans Member Business Loan Act (S. 539; H.R. 4867); Support NCUA Central Liquidity Facility Enhancements (S. 544); Support Neighborhood Homes Investment Act (S. 657); Support CDFI Bond Guarantee Program Improvement Act (S. 869); Support Small LENDER Act (H.R. 1806); Support Transparency in CFPB Cost-Benefit Analysis Act (H.R. 1313); Support Making the CFPB Accountable to Small Businesses Act (H.R. 1749); Support Resolution of Disapproval of the CFPBs Section 1071 final rule (H.J.Res. 50; H.J.Res. 66; H.J.Res. 85; S.J.Res. 32) Support CFPB Transparency and Accountability Reform Act (H.R. 2798); Support SAFE Banking Act (H.R. 2891; S. 1323); Support CDFI Fund Transparency Act (H.R. 3161; S. 2674); Support Building Credit Access for Veterans Act (H.R. 1266); Support Increasing Financial Regulatory Accountability and Transparency Act (H.R. 3556); Support Middle Class Borrower Protection Act (H.R. 3564; S. 2296); Support Digital Dollar Pilot Prevention Act (H.R. 3712); Oppose Credit Card Competition Act (H.R. 3881; S. 1838); Support Member Business Loan Expansion Act (H.R. 4868); Oppose Senate NDAA amendments on interchange (#177; #425); Support Clarity for Payment Stablecoins Act (H.R. 4766); Support Senate NDAA amendment on financial literacy (#206); Support Homes for Every Local Protector, Educator, and Responder (HELPER) Act (H.R. 3170; S. 1514); Oppose Senate appropriations amendment on interchange (#1161); Oppose Senate appropriations amendments on interest rate caps (#1225; #1285); Oppose Capping Credit Card Interest Rates Act (S. 2760); Support SAFER Banking Act (S. 2860); Oppose Amendment #117 to H.R. 4664; Support Amendment #174 to H.R. 4664; Support provisions of H.R. 4664 to place CFPB under the regular appropriations process and restructure the Bureau to a bipartisan commission; Support Rectifying UDAAP Act (H.R. 6789); Support Close the Shadow Banking Loophole Act (S. 3538); Oppose Predatory Lending Elimination Act (S. 3549); Comments to NCUA on OMB Number: 3133-NEW supporting streamlined speaker request forms and increased transparency in speaker request process; Comments to Office of the National Cyber Director on RIN: 0301-AA00 supporting regulatory harmonization and minimizing overlapping or conflicting requirements; Comments to CFPB on Outline of FCRA Proposals supporting adherence to Congressional intent and reissuance of proposals with more detail and specificity; Comments to Department of Labor on RIN 1235-AA39 opposing automatic adjustments and encouraging accommodation of smaller credit unions; Comments to NCUA on proposed 2024-2025 budget opposing unsustainable budget increases and encouraging cost-savings and transparency; Comments to OMB on OMB-2023-0020 supporting increased transparency on agencies use of artificial intelligence technology; Comments to NCUA on Docket No. NCUA-2023-0082 supporting simplification of share insurance for trust accounts; Comments to CFPB on Docket No. CFPB-2023-0052 opposing the proposal and urging CFPB to reduce burden on credit unions and adopt a safe harbor for data providers; Support FHFA publishing data and analysis related to credit score model validation; Support regulatory cost-benefit analysis that includes cumulative effects of regulations; Support extension of comment deadline for Federal Reserve proposal on decreasing the debit interchange fee cap (Docket No. R‐1818); Support extension of comment deadline for CFPB proposal on personal financial data rights (Docket No. CFPB-2023-0052); Support CFPB transparency on its use of artificial intelligence technology; Support NCUA transparency on initiatives to support financial technology innovation; Support NCUA creating a regulatory sandbox to support financial technology innovation; Support a delay in the effective date for the CFPBs Section 1071 final rule for all covered entities; Support NCUA raising commercial loan threshold to $250,000 from current level of $50,000; Support CFPB convening SBREFA panels for credit card late fee rulemaking; Oppose Regulation E liability for financial institutions for consumer-authorized transactions; Support FHFA reopening seasoned bulk transactions window.

Client expense: $960,000 · Firm income: Not reported

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

Protect the credit union tax exemption; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 138 million members; Support regulatory relief for credit unions; Provide guidance or rulemakings rather than rule through enforcement; Support increase in funding for CDFI Fund, MDIs, and the CDRLF; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; Support extending GLBA like data security measures to retailers and fintechs; Support recognizing GLBA compliance in any privacy legislation; Oppose private right of action in data privacy legislation; Support NCUA as credit unions sole data privacy regulator; Oppose opt-in requirement for use of non-public personal information in data privacy legislation; Support federal preemption of state data privacy laws; Oppose NCUA examination authority for 3rd party vendors; Support vendor information sharing among financial regulators; Support adjusting Dodd-Frank Act thresholds for inflation; Support legislative action to limit Regulation E liability; Support fair distribution of Regulation E error resolution responsibilities; Support greater investment authorities for credit unions; Support expansion of Low-Income Housing Tax Credit; Support publication of list of entities with access to Federal Reserve Bank accounts and services; Support legislative action to clarify CFPBs UDAAP authority; Support parity in credit union and bank federal deposit insurance levels; Oppose SBA direct lending authority; Oppose fintech participation in SBA lending programs; Prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; CFPB should engage in interagency coordination on Section 1033 consumer access to financial records rulemaking; Oppose CFPBs characterization of regulated and disclosed financial services fees as junk fees; CFPB should explore streamlining required fee disclosures; Oppose mandatory grace period for credit card late payments; CFPB should clarify UDAAP authority; CFPB should respect GLBAs data security regulatory structure; CFPB should limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); Improve examination coordination between CFPB and NCUA; Support CFPB exercise of larger participant authority to oversee fintech companies; Support clear regulatory framework for digital assets to encourage responsible innovation and permit credit union participation; Support CDFI Fund transparency on certification changes; Oppose changes to CDFI Fund certification process; Support Congressional oversight of SBAs Affiliation and Small Business Lending Company final rules; Support legislation to limit impact of SBAs Affiliation and Small Business Lending Company final rules; Support tax deduction for mortgage insurance premiums; Support modification or removal of the credit union member business lending cap; Support increasing credit union loan maturity limits; Support allowing credit unions to add underserved areas to their FOM; Support increasing the credit union interest rate ceiling; Support credit union Community Reinvestment Act exemption; Support regulator-approved credit union mergers; Support regulation of credit reporting agencies and credit repair organizations; Oppose legislation granting for-profit banks nominal leases on military installations; Support credit union access to nominal leases on military installations; Support alternative credit scoring models; Oppose exclusion of accurate information from credit reports; Support FinCEN funding; Support FinCEN oversight; Support increasing SAR and CTR thresholds; Support disbursal of ECIP funding; Oppose NCUA acting as a climate regulator; Support credit union eligibility for the Greenhouse Gas Reduction Fund; Support Congressional oversight of the Federal Reserve Overnight Reverse Repo Facility; FCC should tailor robocall and robotexts regulations to allow credit unions to serve their members; Support placing CFPB under regular appropriations process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs and consider wealth-building home loan pilot programs; Oppose increase in FHFA guarantee fees; Support regulation of fintechs in mortgage lending; Support alternative credit scoring models; Oppose development of a CBDC; Support prevention of an NFIP lapse; Support improving veterans access to capital by exempting credit unions business loans to veterans from the credit union member business lending cap; Support expanding the definition of Community Financial Institutions (CFIs) in the Federal Home Loan Bank Act (FHLB Act) to include credit unions and Treasury-certified non-depository community development financial institutions; Support government guarantees to stabilize mortgage-backed securities market; Support pilot programs for wealth-building home loans and zero-down mortgages; Support quality- rather than quantity-based GSE loan pricing; Oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; Support parity for credit unions related to stablecoin regulation; Treasury should address the demand for coins to help consumers who rely on cash transactions; Support addressing appraisal bias and modernize the appraisal process for consistency; Support easing requirements for de novo credit unions; Support providing flexibility for credit unions to issue subordinated debt; Support improvements to ease the process for forgiveness of PPP loans to small businesses; Oppose limits on fee income for credit unions including courtesy pay; Support limiting burdens of HMDA rule on credit unions; CFPB should remove unnecessary and unused data points related to HMDA reporting; Support permanently increasing reporting thresholds for open- and closed-end loans; Support permanent adoption of CFPBs expired temporary relief of E-SIGN regulation; Support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support Credit Union Board Modernization Act (H.R. 582; S. 610); Support Promoting Access to Capital in Underbanked Communities Act (H.R. 758); Support Promoting New and Diverse Depository Institutions Act (H.R. 1533; S. 2252); Support Consumer Financial Protection Commission Act (H.R. 1410); Support SECURE Notarization Act (H.R. 1059; S. 1212); Support Prohibiting IRS Financial Surveillance Act (H.R. 1010; S. 453); Support CBDC Anti-Surveillance State Act (H.R. 1122; H.R. 5403); Support Data Privacy Act (H.R. 1165); Support Veterans Member Business Loan Act (S. 539; H.R. 4867); Support NCUA Central Liquidity Facility Enhancements (S. 544); Support Neighborhood Homes Investment Act (S. 657); Support CDFI Bond Guarantee Program Improvement Act (S. 869); Support Small LENDER Act (H.R. 1806); Support Transparency in CFPB Cost-Benefit Analysis Act (H.R. 1313); Support Making the CFPB Accountable to Small Businesses Act (H.R. 1749); Support Resolution of Disapproval of the CFPBs Section 1071 final rule (H.J.Res. 50; H.J.Res. 66; H.J.Res. 85; S.J.Res. 32) Support CFPB Transparency and Accountability Reform Act (H.R. 2798); Support SAFE Banking Act (H.R. 2891; S. 1323); Support CDFI Fund Transparency Act (H.R. 3161; S. 2674); Support Building Credit Access for Veterans Act (H.R. 1266); Support Increasing Financial Regulatory Accountability and Transparency Act (H.R. 3556); Support Middle Class Borrower Protection Act (H.R. 3564; S. 2296); Support Digital Dollar Pilot Prevention Act (H.R. 3712); Oppose Credit Card Competition Act (H.R. 3881; S. 1838); Support Member Business Loan Expansion Act (H.R. 4868); Oppose Senate NDAA amendments on interchange (#177; #425); Support Clarity for Payment Stablecoins Act (H.R. 4766); Support Senate NDAA amendment on financial literacy (#206); Support Homes for Every Local Protector, Educator, and Responder (HELPER) Act (H.R. 3170; S. 1514); Oppose Senate appropriations amendment on interchange (#1161); Oppose Senate appropriations amendments on interest rate caps (#1225; #1285); Oppose Capping Credit Card Interest Rates Act (S. 2760); Support SAFER Banking Act (S. 2860); Comments to NCUA, OCC, Federal Reserve, FDIC, and CFPB on Docket No. NCUA-2023-0061 urging the use of guidance rather than regulations to address reconsiderations of value for residential real estate valuations; Comments to NCUA on Docket No. NCUA-2023-0072 recommending a $5 million asset exemption threshold for NCUA operating fees, offsetting lost revenue through budget reductions, and additional detail and transparency on alternative operating fee schedule methodologies; Comments to NCUA on Docket No. NCUA-2023-0070 supporting the MDI Preservation Program; Comments to NCUA, OCC, Federal Reserve, FDIC, CFPB, and FHFA on Docket No. NCUA-2023-0019 supporting a principles-based approach to regulations on automated valuation models and flexibility for financial institutions, opposing a redundant non-discrimination control factor, and encouraging the establishment of an independent standards setting organization for AVMs; Comments to FHFA on the single family mortgage pricing framework RFI advocating for lower guarantee fees, decreased base risk-weight for high quality credit union mortgages, elimination of fees for disadvantaged borrowers; and the reinstatement of purchases of seasoned transactions; Comments to FCC on CG Docket No. 17-59 and WC Docket No. 17-97 urging the Commission to protect lawful communications credit unions make in its efforts to combat illegal robocalls and robotexts; Comments to FCC on CG Docket No. 02-278 urging the Commission to provide flexibility in processing consumers revocation of consent to receive robocalls and robotexts; Comments to NCUA on Docket No. NCUA-2023-0043 in support of adding 501(c)(19) veterans organizations to the NCUA qualified charity and urging clarification of war veteran terminology; Comments to CFPB on Docket No. CFPB-2023-0029 supporting ability-to-repay requirements for PACE financing; Comments to CFPB on Docket No. CFPB-2023-0020 supporting action to address regulatory gaps in the supervision of data brokers without impairing credit unions ability to access data necessary for competition or increasing regulatory burden on GLBA-covered institutions; Comments to CFPB on Docket No. CFPB-2023-0018 urging clear rules on the prohibition of abusive acts or practices; Support NCUA transparency on initiatives to support financial technology innovation; Support NCUA creating a regulatory sandbox to support financial technology innovation; Support a delay in the effective date for the CFPBs Section 1071 final rule for all covered entities; Support NCUA raising commercial loan threshold to $250,000 from current level of $50,000; Support CFPB convening SBREFA panels for credit card late fee rulemaking; Oppose Regulation E liability for financial institutions for consumer-authorized transactions; Support FHFA reopening seasoned bulk transactions window.

Client expense: $960,000 · Firm income: Not reported

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

Protect the credit union tax exemption; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 138 million members; Support regulatory relief for credit unions; Provide guidance or rulemakings rather than rule through enforcement; Support increase in funding for CDFI Fund, MDIs, and the CDRLF; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; Support extending GLBA like data security measures to retailers and fintechs; Support recognizing GLBA compliance in any privacy legislation; Oppose private right of action in data privacy legislation; Support NCUA as credit unions sole data privacy regulator; Oppose opt-in requirement for use of non-public personal information in data privacy legislation; Support federal preemption of state data privacy laws; Oppose NCUA examination authority for 3rd party vendors; Support vendor information sharing among financial regulators; Support adjusting Dodd-Frank Act thresholds for inflation; Support legislative action to limit Regulation E liability; Support fair distribution of Regulation E error resolution responsibilities; Support greater investment authorities for credit unions; Support expansion of Low-Income Housing Tax Credit; Support publication of list of entities with access to Federal Reserve Bank accounts and services; Support legislative action to clarify CFPBs UDAAP authority; Support parity in credit union and bank federal deposit insurance levels; Oppose SBA direct lending authority; Oppose fintech participation in SBA lending programs; Prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; CFPB should engage in interagency coordination on Section 1033 consumer access to financial records rulemaking; Oppose CFPBs characterization of regulated and disclosed financial services fees as junk fees; CFPB should explore streamlining required fee disclosures; Oppose mandatory grace period for credit card late payments; CFPB should clarify UDAAP authority; CFPB should respect GLBAs data security regulatory structure; CFPB should limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); Improve examination coordination between CFPB and NCUA; Support CFPB exercise of larger participant authority to oversee fintech companies; Support clear regulatory framework for digital assets to encourage responsible innovation and permit credit union participation; Support CDFI Fund transparency on certification changes; Oppose changes to CDFI Fund certification process; Support Congressional oversight of SBAs Affiliation and Small Business Lending Company final rules; Support legislation to limit impact of SBAs Affiliation and Small Business Lending Company final rules; Support tax deduction for mortgage insurance premiums; Support modification or removal of the credit union member business lending cap; Support increasing credit union loan maturity limits; Support allowing credit unions to add underserved areas to their FOM; Support increasing the credit union interest rate ceiling; Support credit union Community Reinvestment Act exemption; Support regulator-approved credit union mergers; Support regulation of credit reporting agencies and credit repair organizations; Oppose legislation granting for-profit banks nominal leases on military installations; Support credit union access to nominal leases on military installations; Support alternative credit scoring models; Oppose exclusion of accurate information from credit reports; Support FinCEN funding; Support FinCEN oversight; Support increasing SAR and CTR thresholds; Support disbursal of ECIP funding; Oppose NCUA acting as a climate regulator; Support credit union eligibility for the Greenhouse Gas Reduction Fund; Support Congressional oversight of the Federal Reserve Overnight Reverse Repo Facility; FCC should tailor robocall and robotexts regulations to allow credit unions to serve their members; Support placing CFPB under regular appropriations process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs and consider wealth-building home loan pilot programs; Oppose increase in FHFA guarantee fees; Support regulation of fintechs in mortgage lending; Support alternative credit scoring models; Oppose development of a CBDC; Support prevention of an NFIP lapse; Support improving veterans access to capital by exempting credit unions business loans to veterans from the credit union member business lending cap; Support expanding the definition of Community Financial Institutions (CFIs) in the Federal Home Loan Bank Act (FHLB Act) to include credit unions and Treasury-certified non-depository community development financial institutions; Support government guarantees to stabilize mortgage-backed securities market; Support pilot programs for wealth-building home loans and zero-down mortgages; Support quality- rather than quantity-based GSE loan pricing; Oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; Support parity for credit unions related to stablecoin regulation; Treasury should address the demand for coins to help consumers who rely on cash transactions; Support addressing appraisal bias and modernize the appraisal process for consistency; Support easing requirements for de novo credit unions; Support providing flexibility for credit unions to issue subordinated debt; Support improvements to ease the process for forgiveness of PPP loans to small businesses; Oppose limits on fee income for credit unions including courtesy pay; Support limiting burdens of HMDA rule on credit unions; CFPB should remove unnecessary and unused data points related to HMDA reporting; Support permanently increasing reporting thresholds for open- and closed-end loans; Support permanent adoption of CFPBs expired temporary relief of E-SIGN regulation; Support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support Credit Union Board Modernization Act (H.R. 582; S. 610); Support Promoting Access to Capital in Underbanked Communities Act (H.R. 758); Support Promoting New and Diverse Depository Institutions Act (H.R. 1533; S. 2252); Support Consumer Financial Protection Commission Act (H.R. 1410); Support SECURE Notarization Act (H.R. 1059; S. 1212); Support Prohibiting IRS Financial Surveillance Act (H.R. 1010; S. 453); Support CBDC Anti-Surveillance State Act (H.R. 1122; H.R. 5403); Support Data Privacy Act (H.R. 1165); Support Veterans Member Business Loan Act (S. 539; H.R. 4867); Support NCUA Central Liquidity Facility Enhancements (S. 544); Support Neighborhood Homes Investment Act (S. 657); Support CDFI Bond Guarantee Program Improvement Act (S. 869); Support Small LENDER Act (H.R. 1806); Support Transparency in CFPB Cost-Benefit Analysis Act (H.R. 1313); Support Making the CFPB Accountable to Small Businesses Act (H.R. 1749); Support Resolution of Disapproval of the CFPBs Section 1071 final rule (H.J.Res. 50; H.J.Res. 66; H.J.Res. 85; S.J.Res. 32) Support CFPB Transparency and Accountability Reform Act (H.R. 2798); Support SAFE Banking Act (H.R. 2891; S. 1323); Support CDFI Fund Transparency Act (H.R. 3161; S. 2674); Support Building Credit Access for Veterans Act (H.R. 1266); Support Increasing Financial Regulatory Accountability and Transparency Act (H.R. 3556); Support Middle Class Borrower Protection Act (H.R. 3564; S. 2296); Support Digital Dollar Pilot Prevention Act (H.R. 3712); Oppose Credit Card Competition Act (H.R. 3881; S. 1838); Support Member Business Loan Expansion Act (H.R. 4868); Oppose Senate NDAA amendments on interchange (#177; #425); Support Clarity for Payment Stablecoins Act (H.R. 4766); Support Senate NDAA amendment on financial literacy (#206); Support Homes for Every Local Protector, Educator, and Responder (HELPER) Act (H.R. 3170; S. 1514); Oppose Senate appropriations amendment on interchange (#1161); Oppose Senate appropriations amendments on interest rate caps (#1225; #1285); Oppose Capping Credit Card Interest Rates Act (S. 2760); Support SAFER Banking Act (S. 2860); Comments to NCUA, OCC, Federal Reserve, FDIC, and CFPB on Docket No. NCUA-2023-0061 urging the use of guidance rather than regulations to address reconsiderations of value for residential real estate valuations; Comments to NCUA on Docket No. NCUA-2023-0072 recommending a $5 million asset exemption threshold for NCUA operating fees, offsetting lost revenue through budget reductions, and additional detail and transparency on alternative operating fee schedule methodologies; Comments to NCUA on Docket No. NCUA-2023-0070 supporting the MDI Preservation Program; Comments to NCUA, OCC, Federal Reserve, FDIC, CFPB, and FHFA on Docket No. NCUA-2023-0019 supporting a principles-based approach to regulations on automated valuation models and flexibility for financial institutions, opposing a redundant non-discrimination control factor, and encouraging the establishment of an independent standards setting organization for AVMs; Comments to FHFA on the single family mortgage pricing framework RFI advocating for lower guarantee fees, decreased base risk-weight for high quality credit union mortgages, elimination of fees for disadvantaged borrowers; and the reinstatement of purchases of seasoned transactions; Comments to FCC on CG Docket No. 17-59 and WC Docket No. 17-97 urging the Commission to protect lawful communications credit unions make in its efforts to combat illegal robocalls and robotexts; Comments to FCC on CG Docket No. 02-278 urging the Commission to provide flexibility in processing consumers revocation of consent to receive robocalls and robotexts; Comments to NCUA on Docket No. NCUA-2023-0043 in support of adding 501(c)(19) veterans organizations to the NCUA qualified charity and urging clarification of war veteran terminology; Comments to CFPB on Docket No. CFPB-2023-0029 supporting ability-to-repay requirements for PACE financing; Comments to CFPB on Docket No. CFPB-2023-0020 supporting action to address regulatory gaps in the supervision of data brokers without impairing credit unions ability to access data necessary for competition or increasing regulatory burden on GLBA-covered institutions; Comments to CFPB on Docket No. CFPB-2023-0018 urging clear rules on the prohibition of abusive acts or practices; Support NCUA transparency on initiatives to support financial technology innovation; Support NCUA creating a regulatory sandbox to support financial technology innovation; Support a delay in the effective date for the CFPBs Section 1071 final rule for all covered entities; Support NCUA raising commercial loan threshold to $250,000 from current level of $50,000; Support CFPB convening SBREFA panels for credit card late fee rulemaking; Oppose Regulation E liability for financial institutions for consumer-authorized transactions; Support FHFA reopening seasoned bulk transactions window.

Client expense: $960,000 · Firm income: Not reported

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