Promoting New and Diverse Depository Institutions Act

Bank On Certification Program Central Bank Digital Currency Cryptocurrency Deposit Insurance Digital Assets Bank Capital Requirements/Basel Capital Proposal Postal Banking S.1323 & H.R.2891, Secure and Fair Enforcement (SAFE) Banking Act of 2023 H.R.4177 & S.2007, Improving Corporate Governance Through Diversity Act of 2023 H.R.2547, Comprehensive Debt Collection Improvement Act S.3937 & H.R.758, Promoting Access to Capital in Underbanked Communities Act of 2023 H.R. 1533 & S. 2252, Promoting New and Diverse Depository Institutions Act Emergency Capital Investment Issues for CDFI and MDI H.R.7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on banking UDAAP Supervisory Policies and Adjudication Procedures Community Reinvestment Act Final Rule Deposit Insurance Issues S.1838 & H.R.3881 Credit Card Competition Act of 2023 S.4760, Digital Commodities Consumer Protection Act of 2022 Merchant Category Codes S.1790, Failed Bank Executives Clawback Act S.293 & H.R.2743, Fair Access to Banking Act H.R.2799, Expanding Access to Capital Act of 2023 H.R.2603, To require the Securities and Exchange Commission to revise certain thresholds related to smaller reporting companies, accelerated filers, and large accelerated filers, and for other purposes H.R.2798, Consumer Financial Protection Bureau Transparency and Accountability Reform Act H.R.1382, TABS Act of 2023 H.R.1411, Consumer Financial Protection Bureau-Inspector General Reform Act H.R.2489, the Consumer Financial Protection Bureau Dual Mandate and Economic Analysis Act H.R.1313, the Transparency in Consumer Financial Protection Bureau Cost-Benefit Analysis Act H.R.1719, Making the Consumer Financial Protection Bureau Accountable to Small Business Act S.1362, the Transparency in Consumer Financial Protection Bureau Cost-Benefit Analysis Act H.R.490, Federal Infrastructure Bank Act of 2023 H.R.4868, Member Business Loan Expansion Act H.R.4035, Protecting Small Business Information Act of 2023 S.2760, Capping Credit Card Interest Rates Act H.R.5485, Financial Privacy Act of 2023 H.R.5524, Foreign Affiliate Sharing Pilot Program H.R.5403, Central Bank Digital Currency Anti-Surveillance Act H.R.5741, Uniform Treatment of Custodial Assets Act S.2860, Secure and Fair Enforcement Regulation (SAFER) Banking Act H.R.4763, Financial Innovation and Technology for the 21st Century Act H.R.4766, Clarity for Payment Stablecoins Act of 2023 S.2190, Recovering Executive Compensation Obtained Through Unaccountable Practices (RECOUP) Act of 2023 S.2251, Federal Information Security Modernization Act H.R.3398, Safe Access to Cash Act of 2023 S.3549, the Predatory Lending Elimination Act H.R.6789, Rectifying UDAAP Act H.R.1810, Bank Loan Privacy Act H.R.1806/S.1159, Small Lender Act H.R.4346, Small Bank Holding Company Relief Act of 2023 H.R.4198, Protecting Consumers from Abusive Mortgage Leads Act Regulation II: Debit Card Interchange Fees and Routing Implementation of Dodd-Frank Act Section 1033: Proposed Rule on Personal Financial Data Rights Merger and Acquisition Policy S.3554, Financial Artificial Intelligence Risk Reduction Act CDFI Certification Update H.R.7531 & S.4570, Secure Payments Act of 2024 H.R.7437, Fostering Use of Technology to Uphold Regulatory Effectiveness in Supervision Act (FUTURES Act) H.R.4206, Bank Safety Act H.J.Res.122 & S.J.Res.70, Providing for Congressional disapproval under Chapter 8 of Title 5, U.S. Code, of the rule submitted by the Consumer Financial Protection Bureau related to Credit Card Penalty Fees (Reg Z) Notice of Proposed Rulemaking for Debit Card Interchange Fees and Routing (Reg II) Department of Labor Fiduciary Rule H.J.Res.140, 141, 142, and 143-Congressional Review Act Resolutions of Disapproval of the Department of Labor Fiduciary Rule S.J.Res.79, Congressional Review Act Resolution of Disapproval of the Department of Labor Fiduciary Rule Federal Reserve Discount Window and Emergency Lending Authority Guidelines for Establishing Standards for Corporate Governance and Risk Management for Covered Institutions with Total Consolidated Assets of $10 Billion or More CFPB Larger Participant of a Market for General-Use Digital Consumer Payment Applications H.R.8337, Bank Resilience and Regulatory Improvement Act H.R.8338, Clarity in Lending Act H.R.8288, Bringing the Discount Window into the 21st Century Act H.R.8287, Stress Testing Accountability and Transparency Act H.R.8264, Bank Supervision Appeals Improvement Act of 2024 H.R.8356, Small Dollar Loan Certainty Act H.R.7403, Bank Failure Prevention Act of 2024H.R.7437, Fostering the Use of Technology to Uphold Regulatory Effectiveness in Supervision (FUTURES) Act H.R.4206, Bank Safety Act Tokenization of Assets Fraud Issues FDIC Proposed Guidelines for Corporate Governance and Risk Management for Banks Over $10 Billion in Assets Pilot program allowing Freddie Mac to purchase single family closed-end second mortgages National Bank Act & Defending Dual Banking System

Client expense: $1,490,000 · Firm income: Not reported

Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

S. 293 Fair Access to Banking Act 2023. S. 245 Financial Institution Customer Protection Act 2023. S. 817/HR. 1602 SVB Act. HR. 1663 Critical Bank Review Act. HR. 758 Promoting Access to Capital in Underbanked Communities Act of 2023. S. 362 TAILOR Act of 2023. S. 583 FDIC Act of 2023. HR. 1810 Bank Privacy Act. HR. 1533 Promoting New and Diverse Depository Institutions Act. HR. 1410 Consumer Financial Protection Commission Act. HR. 500 Financial Exploitation Prevention Act of 2023. HR. 1382 TABS Act of 2023. S.2190 Recovering Executive Compensation From Unaccountable Practices Act (RECOUP Act). S.1045 Failed Bank Executives Clawback Act. S.1838 The Credit Card Competition Act. HR. 1165 The Data Privacy Act of 2023. Issues related to Capital One/Discover merger, banking, payments, lending and payments innovation.

Client expense: $430,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

S. 293 Fair Access to Banking Act 2023. S. 245 Financial Institution Customer Protection Act 2023. S. 817/HR. 1602 SVB Act. HR. 1663 Critical Bank Review Act. HR. 758 Promoting Access to Capital in Underbanked Communities Act of 2023. S. 362 TAILOR Act of 2023. S. 583 FDIC Act of 2023. HR. 1810 Bank Privacy Act. HR. 1533 Promoting New and Diverse Depository Institutions Act. HR. 1410 Consumer Financial Protection Commission Act. HR. 500 Financial Exploitation Prevention Act of 2023. HR. 1382 TABS Act of 2023. S.2190 Recovering Executive Compensation From Unaccountable Practices Act (RECOUP Act). S.1045 Failed Bank Executives Clawback Act. S.1838 The Credit Card Competition Act. HR. 1165 The Data Privacy Act of 2023. Issues related to banking, payments, lending and payments innovation.

Client expense: $620,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

Bank On Central Bank Digital Currency Cryptocurrency Deposit Insurance Digital Assets Bank Capital Requirements/Basel Capital Proposal Postal Banking S.1323 & H.R.2891, Secure and Fair Enforcement (SAFE) Banking Act of 2023 H.R. 4177 & S. 2007, Improving Corporate Governance Through Diversity Act of 2023 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 758, Promoting Access to Capital in Underbanked Communities Act of 2023 H.R.4590, Promoting New and Diverse Depository Institutions Act H.R. 1533, Promoting New and Diverse Depository Institutions Act Emergency Capital Investment Issues for CDFI and MDI H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on Banking UDAAP Supervisory Policies and Adjudication Procedures Community Reinvestment Act Final Rule Deposit Insurance Issues S.1838, Credit Card Competition Act of 2023 H.R. 3881, Credit Card Competition Act of 2023 S.4760, Digital Commodities Consumer Protection Act of 2022 Merchant Category Codes S.1790, Failed Bank Executives Clawback Act S.293 & H.R. 2743, Fair Access to Banking Act H.R. 2799, Expanding Access to Capital Act of 2023 H.R. 2603, To require the Securities and Exchange Commission to revise certain thresholds related to smaller reporting companies, accelerated filers, and large accelerated filers, and for other purposes H.R. 2798, Consumer Financial Protection Bureau Transparency and Accountability Reform Act H.R. 1382, TABS Act of 2023 H.R. 1411, Consumer Financial Protection Bureau-Inspector General Reform Act H.R. 2489, the Consumer Financial Protection Bureau Dual Mandate and Economic Analysis Act H.R. 1313, the Transparency in Consumer Financial Protection Bureau Cost-Benefit Analysis Act H.R. 1719, Making the Consumer Financial Protection Bureau Accountable to Small Business Act S.1362, the Transparency in Consumer Financial Protection Bureau Cost-Benefit Analysis Act H.R. 490, Federal Infrastructure Bank Act of 2023 H.R. 4868, Member Business Loan Expansion Act H.R. 4035, Protecting Small Business Information Act of 2023 S.2760, Capping Credit Card Interest Rates Act H.R. 5485, Financial Privacy Act of 2023 H.R. 5524, Foreign Affiliate Sharing Pilot Program H.R. 5403, Central Bank Digital Currency Anti-Surveillance Act H.R. 5741, Uniform Treatment of Custodial Assets Act S. 2860, Secure and Fair Enforcement Regulation (SAFER) Banking Act H.R. 4763, Financial Innovation and Technology for the 21st Century Act H.R. 4766, Clarity for Payment Stablecoins Act of 2023 S. 2190, Recovering Executive Compensation Obtained Through Unaccountable Practices (RECOUP) Act of 2023 S. 2251, Federal Information Security Modernization Act H.R. 3398, Safe Access to Cash Act of 2023 S. 3549, the Predatory Lending Elimination Act H.R. 6789, Rectifying UDAAP Act H.R. 1810, Bank Loan Privacy Act H.R. 1806/S. 1159, Small Lender Act H.R. 4346, Small Bank Holding Company Relief Act of 2023 H.R. 4198, Protecting Consumers from Abusive Mortgage Leads Act Regulation II: Debit Card Interchange Fees and Routing Implementation of Dodd-Frank Act Section 1033:Proposed Rule on Personal Financial Data Rights Department of Labor Retirement Security Rule: Definition of an Investment Advice Fiduciary (Fiduciary Rule) S.3554, Financial Artificial Intelligence Risk Reduction Act CDFI Certification Update H.R. 7531, Secure Payments Act of 2024 H.R. 7437, Fostering Use of Technology to Uphold Regulatory Effectiveness in Supervision Act (FUTURES Act) H.R. 4206, Bank Safety Act H.J. Res. 122/S.J, Res. 70, Providing for Congressional disapproval under Chapter 8 of Title 5, U.S. Code, of the rule submitted by the Consumer Financial Protection Bureau related to Credit Card Penalty Fees (Reg Z) H.R. 6789, Rectifying UDAAP Act Notice of Proposed Rulemaking for Debit Card Interchange Fees and Routing (Reg II) Department of Labor Fiduciary Proposal Department of Labor Overtime Proposal Federal Reserve Discount Window and Emergency Lending Authority Guidelines for Establishing Standards for Corporate Governance and Risk Management for Covered Institutions with Total Consolidated Assets of $10 Billion or More CFPB Larger Participant of a Market for General-Use Digital Consumer Payment Applications

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.

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.

Bank On Central Bank Digital Currency Cryptocurrency Deposit Insurance Digital Assets Nominations Bank Capital Requirements/Basel Capital Proposal Postal Banking S.1323 & H.R.2891, Secure and Fair Enforcement (SAFE) Banking Act of 2023 H.R. 4177 & S. 2007, Improving Corporate Governance Through Diversity Act of 2023 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 758, Promoting Access to Capital in Underbanked Communities Act of 2023 H.R.4590, Promoting New and Diverse Depository Institutions Act H.R. 1533, Promoting New and Diverse Depository Institutions Act Emergency Capital Investment Issues for CDFI and MDI H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. H.R. 7003, Expanding Financial Access for Underserved Communities Act S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on Banking. UDAAP Supervisory Policies and Adjudication Procedures Community Reinvestment Act modernization Deposit Insurance Assessment Rates S.1838, Credit Card Competition Act of 2023 H.R. 3881, Credit Card Competition Act of 2023 S.4760, Digital Commodities Consumer Protection Act of 2022 Merchant Category Codes S.1790, Failed Bank Executives Clawback Act S.293 & H.R. 2743, Fair Access to Banking Act H.R. 2799, Expanding Access to Capital Act of 2023 H.R. 2603, To require the Securities and Exchange Commission to revise certain thresholds related to smaller reporting companies, accelerated filers, and large accelerated filers, and for other purposes H.R. 2798, Consumer Financial Protection Bureau Transparency and Accountability Reform Act H.R. 1382, TABS Act of 2023 H.R. 1411, Consumer Financial Protection Bureau-Inspector General Reform Act H.R. 2489, the Consumer Financial Protection Bureau Dual Mandate and Economic Analysis Act H.R. 1313, the Transparency in Consumer Financial Protection Bureau Cost-Benefit Analysis Act H.R. 1719, Making the Consumer Financial Protection Bureau Accountable to Small Business Act S.1362, the Transparency in Consumer Financial Protection Bureau Cost-Benefit Analysis Act H.R. 490, Federal Infrastructure Bank Act of 2023 H.R. 4868, Member Business Loan Expansion Act H.R. 4035, Protecting Small Business Information Act of 2023 S.2760, Capping Credit Card Interest Rates Act H.R. 5485, Financial privacy Act of 2023 H.R. 5524, Foreign Affiliate Sharing Pilot Program H.R. 5403, Central Bank Digital Currency Anti-Surveillance Act H.R. 5741, Uniform Treatment of Custodial Assets Act S. 2860, Secure and Fair Enforcement Regulation (SAFER) Banking Act H.R. 4763, Financial Innovation and Technology for the 21st Century Act H.R. 4766, Clarity for Payment Stablecoins Act of 2023 S. 2190, Recovering Executive Compensation Obtained Through Unaccountable Practices (RECOUP) Act of 2023 S. 2251, Federal Information Security Modernization Act H.R. 3398, Safe Access to Cash Act of 2023 S. 3549, the Predatory Lending Elimination Act H.R. 6789, Rectifying UDAAP Act H.R. 1810, Bank Loan Privacy Act H.R. 1806/S. 1159, Small Lender Act H.R. 4346, Small Bank Holding Company Relief Act of 2023 H.R. 4198, Protecting Consumers from Abusive Mortgage Leads Act S. 3502, Homebuyers Privacy Protection Act Regulation II: Debit Card Interchange Fees and Routing Implementation of Dodd-Frank Act Section 1033-- Proposed Rule on Personal Financial Data Rights Department of Labor Retirement Security Rule: Definition of an Investment Advice Fiduciary (Fiduciary Rule) S.3554, Financial Artificial Intelligence Risk Reduction Act CDFI Certification Update

S. 293 Fair Access to Banking Act 2023. S. 245 Financial Institution Customer Protection Act 2023. S. 817/HR. 1602 SVB Act. HR. 1663 Critical Bank Review Act. HR. 758 Promoting Access to Capital in Underbanked Communities Act of 2023. S. 362 TAILOR Act of 2023. S. 583 FDIC Act of 2023. HR. 1810 Bank Privacy Act. HR. 1533 Promoting New and Diverse Depository Institutions Act. HR. 1410 Consumer Financial Protection Commission Act. HR. 500 Financial Exploitation Prevention Act of 2023. HR. 1382 TABS Act of 2023. S.2190 Recovering Executive Compensation From Unaccountable Practices Act (RECOUP Act). S.1045 Failed Bank Executives Clawback Act. S.1838 The Credit Card Competition Act. HR. 1165 The Data Privacy Act of 2023. Issues related to banking, payments, lending and payments innovation.

Client expense: $430,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

Bank On Central Bank Digital Currency Cryptocurrency Deposit Insurance Digital Assets Nominations Bank Capital Requirements Postal Banking S.1323 & H.R.2891, Secure and Fair Enforcement (SAFE) Banking Act of 2023 H.R. 4177& S. 2007, Improving Corporate Governance Through Diversity Act of 2023 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 758, Promoting Access to Capital in Underbanked Communities Act of 2023 H.R.1533, Promoting New and Diverse Depository Institutions Act Emergency Capital Investment Issues for CDFI and MDI H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. H.R.7003, Expanding Financial Access for Underserved Communities Act S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on Banking. UDAAP Supervisory Policies and Adjudication Procedures Community Reinvestment Act modernization Deposit Insurance Assessment Rates S.1838, Credit Card Competition Act H.R. 3881, Credit Card Competition Act S.4760, Digital Commodities Consumer Protection Act of 2022 Merchant Category Codes S.1790--Failed Bank Executives Clawback Act S.293 & H.R. 2743, Fair Access to Banking Act H.R. 2799, Expanding Access to Capital Act of 2023 H.R. 2603, To require the Securities and Exchange Commission to revise certain thresholds related to smaller reporting companies, accelerated filers, and large accelerated filers, and for other purposes H.R. 2798 Consumer Financial Protection Bureau Transparency and Accountability Reform Act H.R.1382 TABS Act of 2023 H.R.1411, Consumer Financial Protection Bureau-Inspector General Reform Act H.R. 2489, the Consumer Financial Protection Bureau Dual Mandate and Economic Analysis Act H.R.1313, the Transparency in Consumer Financial Protection Bureau Cost-Benefit Analysis Act H.R.1719, Making the Consumer Financial Protection Bureau Accountable to Small Business Act S.1362, the Transparency in Consumer Financial Protection Bureau Cost-Benefit Analysis Act H.R. 490, Federal Infrastructure Bank Act of 2023 H.R. 4868, Member Business Loan Expansion Act H.R. 4035, Protecting Small Business Information Act of 2023 S.2760, Capping Credit Card Interest Rates Act H.R. 5485, Financial privacy Act of 2023 H.R. 5524, Foreign Affiliate Sharing Pilot Program H.R. 5403, Central Bank Digital Currency Anti-Surveillance Act H.R. 5741, Uniform Treatment of Custodial Assets Act S.2860, Secure and Fair Enforcement Regulation (SAFER) Banking Act H.R. 4763, Financial Innovation and Technology for the 21st Century Act H.R. 4766, Clarity for Payment Stablecoins Act of 2023 S.2190, Recovering Executive Compensation Obtained Through Unaccountable Practices (RECOUP) Act of 2023 S. 2251, Federal Information Security Modernization Act H.R. 3398, Safe Access to Cash 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 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.

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.

S. 293 Fair Access to Banking Act 2023. S. 245 Financial Institution Customer Protection Act 2023. S. 817/HR. 1602 SVB Act. HR. 1663 Critical Bank Review Act. HR. 758 Promoting Access to Capital in Underbanked Communities Act of 2023. S. 362 TAILOR Act of 2023. S. 583 FDIC Act of 2023. HR. 556 21st Century Dollar Act. S. 293 Fair Access to Banking Act. HR. 1810 Bank Privacy Act. HR. 1409 FDIC Accountability Act. HR. 1533 Promoting New and Diverse Depository Institutions Act. HR. 2489 Amend and Update the CFPB HR. 1410 Consumer Financial Protection Commission Act. HR. 500 Financial Exploitation Prevention Act of 2023. HR. 802 Respect State Housing Laws Act. HR. 1382 TABS Act of 2023. S.2190 Recovering Executive Compensation From Unaccountable Practices Act (RECOUP Act). S.1045 Failed Bank Executives Clawback Act. S.1838 The Credit Card Competition Act. HR. 1165 The Data Privacy Act of 2023. HR. 3021 Protecting the Second Amendment in Financial Services Act. Issues related to banking, payments, and lending.

Client expense: $340,000 · Firm income: Not reported

Bank On Central Bank Digital Currency Cryptocurrency Digital Assets Market Structure Bill (Draft) A Bill to Provide for the Regulation of Payment Stablecoins (Draft) Nominations Postal Banking S.1323 & H.R.2891, Secure and Fair Enforcement (SAFE) Banking Act of 2023 H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 758, Promoting Access to Capital in Underbanked Communities Act of 2023 H.R.1533, Promoting New and Diverse Depository Institutions Act H.R. 6145, Community Bank Relief Act of 2021 S. 3409, To amend the Economic Growth, Regulatory Relief, and Consumer Protection Act 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. Emergency Capital Investment Issues for CDFI and MDI S. 3715, The E-SIGN Modernization Act H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. H.R. 4277, Overdraft Protection Act of 2021 H.R 4521, America Competes Act of 2022 H.R.7003, Expanding Financial Access for Underserved Communities Act S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on Banking. UDAAP Supervisory Policies and Adjudication Procedures Community Reinvestment Act Deposit Insurance Assessment Rates S.1838 , Credit Card Competition Act H.R. 3881, Credit Card Competition Act S.4760, Digital Commodities Consumer Protection Act of 2022 Merchant Category Codes S.1790--Failed Bank Executives Clawback Act S.293 & H.R. 2743, Fair Access to Banking Act H.R. 2799, Expanding Access to Capital Act of 2023 H.R. 2603, To require the Securities and Exchange Commission to revise certain thresholds related to smaller reporting companies, accelerated filers, and large accelerated filers, and for other purposes H.R.2798 Consumer Financial Protection Bureau Transparency and Accountability Reform Act H.R.1382 TABS Act of 2023 H.R.1411, Consumer Financial Protection Bureau-Inspector General Reform Act H.R. 2489, the Consumer Financial Protection Bureau Dual Mandate and Economic Analysis Act H.R.1313, the Transparency in Consumer Financial Protection Bureau Cost-Benefit Analysis Act H.R.1719, Making the Consumer Financial Protection Bureau Accountable to Small Business Act S.1362, the Transparency in Consumer Financial Protection Bureau Cost-Benefit Analysis Act H.R.490, Federal Infrastructure Bank 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 137 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 proposed 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 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); 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); Support Data Privacy Act (H.R. 1165); Support Veterans Member Business Loan Act (S. 539); 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; 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); 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); Support Digital Dollar Pilot Prevention Act (H.R. 3712); Oppose Credit Card Competition Act (H.R. 3881; S. 1838) Comments to CFPB on Docket No. CFPB-2023-0002 opposing inclusion of credit union service organizations in a form contract registry, urging the CFPB to reduce impact on small entities, and supporting arbitration; Comments to Treasury on Docket No. FISCAL-2021-0001 suggesting concentrating check verification within the Federal Reserve Banks; Request deadline extension for the CFPBs credit card terms collection and credit card penalty fees proposed rule; Comments to CFPB on Docket No. CFPB-2023-0009 requesting greater flexibility in required disclosures; Comments to CFPB on Docket No. CFPB-2023-0017 supporting the Mortgage Loan Originator rules; Request the CFPB to share specific concerns that require reanalysis of 2020-22 HMDA filings; Comments to CFPB on Docket No. CFPB-2023-0010 opposing reduction of the credit card late fee safe harbor amounts; Comments to Treasury on ECIP Supplemental Reports (OMB Control Number 1505-0275) opposing a requirement to collect detailed demographic information; Comments to FHFA on RIN: 2590-AB27 supporting changes to GSE capital framework; Request the EPA to support credit union eligibility for the Greenhouse Gas Reduction Fund; Support creation of FHFA single-family social bonds; Comments to CFPB on Docket No. CFPB-2023-0026 opposing the CFPBs PRA request for a Junk Fees Timing Study; Support adding 501(c)(19) veterans organizations to the NCUAs qualified charity definition; Comments to NCUA on Docket No. NCUA-2022-0179 supporting proposed changes to the Chartering and Field of Membership Manual; Request flexible implementation timeline for new FHFA credit score requirements; Comments to NCUA on Docket No. NCUA-2023-0045 urging the NCUA to refrain from engaging in rulemaking related to climate risk and to defer to FSOC on issuing guidance; Comments to NCUA on the agencys annual regulatory review; 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.

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 137 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 proposed 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 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); 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); Support Data Privacy Act (H.R. 1165); Support Veterans Member Business Loan Act (S. 539); 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; 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); 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); Support Digital Dollar Pilot Prevention Act (H.R. 3712); Oppose Credit Card Competition Act (H.R. 3881; S. 1838) Comments to CFPB on Docket No. CFPB-2023-0002 opposing inclusion of credit union service organizations in a form contract registry, urging the CFPB to reduce impact on small entities, and supporting arbitration; Comments to Treasury on Docket No. FISCAL-2021-0001 suggesting concentrating check verification within the Federal Reserve Banks; Request deadline extension for the CFPBs credit card terms collection and credit card penalty fees proposed rule; Comments to CFPB on Docket No. CFPB-2023-0009 requesting greater flexibility in required disclosures; Comments to CFPB on Docket No. CFPB-2023-0017 supporting the Mortgage Loan Originator rules; Request the CFPB to share specific concerns that require reanalysis of 2020-22 HMDA filings; Comments to CFPB on Docket No. CFPB-2023-0010 opposing reduction of the credit card late fee safe harbor amounts; Comments to Treasury on ECIP Supplemental Reports (OMB Control Number 1505-0275) opposing a requirement to collect detailed demographic information; Comments to FHFA on RIN: 2590-AB27 supporting changes to GSE capital framework; Request the EPA to support credit union eligibility for the Greenhouse Gas Reduction Fund; Support creation of FHFA single-family social bonds; Comments to CFPB on Docket No. CFPB-2023-0026 opposing the CFPBs PRA request for a Junk Fees Timing Study; Support adding 501(c)(19) veterans organizations to the NCUAs qualified charity definition; Comments to NCUA on Docket No. NCUA-2022-0179 supporting proposed changes to the Chartering and Field of Membership Manual; Request flexible implementation timeline for new FHFA credit score requirements; Comments to NCUA on Docket No. NCUA-2023-0045 urging the NCUA to refrain from engaging in rulemaking related to climate risk and to defer to FSOC on issuing guidance; Comments to NCUA on the agencys annual regulatory review; 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.

S 293 Fair Access to Banking Act 2023 S 245 Financial Institution Customer Protection Act 2023 S 817/HR 1602 SVB Act HR 1663 Critical Bank Review Act HR 758 Promoting Access to Capital in Underbanked Communities Act of 2023 S 362 TAILOR Act of 2023 S 583 FDIC Act of 2023 HR 556 21st Century Dollar Act S 293 Fair Access to Banking Act HR 1810 Bank Privacy Act HR 1409 FDIC Accountability Act HR 1533 Promoting New and Diverse Depository Institutions Act HR 2489 Amend and Update the CFPB HR 1410 Consumer Financial Protection Commission Act HR 500 Financial Exploitation Prevention Act of 2023 HR 802 Respect State Housing Laws Act HR 1382 TABS Act of 2023 S.2190 Recovering Executive Compensation From Unaccountable Practices Act (RECOUP Act) S.1045 Failed Bank Executives Clawback Act S.1838 The Credit Card Competition Act HR 1165 The Data Privacy Act of 2023 HR 3021 Protecting the Second Amendment in Financial Services Act Issues related to banking, payments, and lending

Client expense: $510,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), SENATE, Treasury, Dept of

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 135 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; Prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; CFPB should engage in interagency coordination on Section 1033 consumer access to financial records rulemaking; Oppose CFPBs characterization of regulated and disclosed financial services fees as junk fees; CFPB should explore streamlining required fee disclosures; CFPB should clarify UDAAP authority; CFPB should respect GLBAs data security regulatory structure; CFPB should limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); Improve examination coordination between CFPB and NCUA; Support 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 proposed rules; Support tax deduction for mortgage insurance premiums; Support modification or removal of the credit union member business lending cap; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; Support alternative credit scoring models; Oppose development of a CBDC; Support prevention of an NFIP lapse; Support improving veterans access to capital by exempting credit unions business loans to veterans from the credit union member business lending cap; Support expanding the definition of Community Financial Institutions (CFIs) in the Federal Home Loan Bank Act (FHLB Act) to include credit unions and Treasury-certified non-depository community development financial institutions; 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); Support Consumer Financial Protection Commission Act (H.R. 1410); Support SECURE Notarization Act (H.R. 1059); Support Prohibiting IRS Financial Surveillance Act (H.R. 1010; S. 453); Support CBDC Anti-Surveillance State Act (H.R. 1122); Support Data Privacy Act (H.R. 1165); Support Veterans Member Business Loan Act (S. 539); 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); Comments to VA on Docket No., VA-2022-VBA-0026 asking for flexibility in VA regulation on guaranteed or insured refinance loans; Comments to SBA on RIN 3245-AH92 expressing concern about allowing unregulated fintechs to participate in government-guaranteed lending programs; Support allowing credit unions to participate in the EPA Greenhouse Gas Reduction Fund; Support NCUA raising commercial loan threshold to $250,000 from current level of $50,000; Comments to Federal Reserve on Docket No. OP-1788 supporting transparency in evaluating account and services requests; Support CFPB convening SBREFA panels for credit card late fee rulemaking; Comments to CFPB on Section 1033 outline of proposals supporting a limited interpretation with greater flexibility for financial institutions; Support NCUA adopting a floating interest rate ceiling; Support NCUA setting a 21 percent interest rate ceiling; Support NCUA extending the 18 percent interest rate ceiling; Comments to CDFI Fund on Docket No. 2022- 27142 opposing changes to certification process; Comments to Federal Reserve on Docket No. R-1748 supporting extension of effective date for Regulation II amendment; Comments to FinCEN on Docket No.: FINCEN-2021-005 recommending FinCEN independently verify beneficial ownership information and establish clear definitions; Support CFPB partnering with state regulators to uphold the Gramm-Leach-Bliley Act; Comments to NCUA on RIN 3133-AF49 and RIN 3133-AE96 supporting greater flexibility in lending authorities; Comments to CFPB on Docket No. CFPB-2023-0010 requesting deadline extension; Comments to FCC on CG Dockets No. 21-402, 02-278 supporting redress mechanisms for text senders; Oppose Regulation E liability for financial institutions for consumer-authorized transactions; Comments to CFPB on Docket No. CFPB-2023-0010 requesting underlying data and analysis; Comments to FinCEN on Docket No.: FINCEN-2023-0002 opposing proposal to allow reporting companies to avoid answering beneficial ownership questions; Support FHFA reopening seasoned bulk transactions window; Comments to CFPB on Docket No. CFPB-2023- 0016 supporting trial disclosure waiver template application; Comments to CFPB on Docket No. CFPB-2022-0024 supporting registration of agency and court orders and requesting greater CFPB supervision of nonbank entities

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 135 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; Prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; CFPB should engage in interagency coordination on Section 1033 consumer access to financial records rulemaking; Oppose CFPBs characterization of regulated and disclosed financial services fees as junk fees; CFPB should explore streamlining required fee disclosures; CFPB should clarify UDAAP authority; CFPB should respect GLBAs data security regulatory structure; CFPB should limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); Improve examination coordination between CFPB and NCUA; Support 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 proposed rules; Support tax deduction for mortgage insurance premiums; Support modification or removal of the credit union member business lending cap; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; Support alternative credit scoring models; Oppose development of a CBDC; Support prevention of an NFIP lapse; Support improving veterans access to capital by exempting credit unions business loans to veterans from the credit union member business lending cap; Support expanding the definition of Community Financial Institutions (CFIs) in the Federal Home Loan Bank Act (FHLB Act) to include credit unions and Treasury-certified non-depository community development financial institutions; 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); Support Consumer Financial Protection Commission Act (H.R. 1410); Support SECURE Notarization Act (H.R. 1059); Support Prohibiting IRS Financial Surveillance Act (H.R. 1010; S. 453); Support CBDC Anti-Surveillance State Act (H.R. 1122); Support Data Privacy Act (H.R. 1165); Support Veterans Member Business Loan Act (S. 539); 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); Comments to VA on Docket No., VA-2022-VBA-0026 asking for flexibility in VA regulation on guaranteed or insured refinance loans; Comments to SBA on RIN 3245-AH92 expressing concern about allowing unregulated fintechs to participate in government-guaranteed lending programs; Support allowing credit unions to participate in the EPA Greenhouse Gas Reduction Fund; Support NCUA raising commercial loan threshold to $250,000 from current level of $50,000; Comments to Federal Reserve on Docket No. OP-1788 supporting transparency in evaluating account and services requests; Support CFPB convening SBREFA panels for credit card late fee rulemaking; Comments to CFPB on Section 1033 outline of proposals supporting a limited interpretation with greater flexibility for financial institutions; Support NCUA adopting a floating interest rate ceiling; Support NCUA setting a 21 percent interest rate ceiling; Support NCUA extending the 18 percent interest rate ceiling; Comments to CDFI Fund on Docket No. 2022- 27142 opposing changes to certification process; Comments to Federal Reserve on Docket No. R-1748 supporting extension of effective date for Regulation II amendment; Comments to FinCEN on Docket No.: FINCEN-2021-005 recommending FinCEN independently verify beneficial ownership information and establish clear definitions; Support CFPB partnering with state regulators to uphold the Gramm-Leach-Bliley Act; Comments to NCUA on RIN 3133-AF49 and RIN 3133-AE96 supporting greater flexibility in lending authorities; Comments to CFPB on Docket No. CFPB-2023-0010 requesting deadline extension; Comments to FCC on CG Dockets No. 21-402, 02-278 supporting redress mechanisms for text senders; Oppose Regulation E liability for financial institutions for consumer-authorized transactions; Comments to CFPB on Docket No. CFPB-2023-0010 requesting underlying data and analysis; Comments to FinCEN on Docket No.: FINCEN-2023-0002 opposing proposal to allow reporting companies to avoid answering beneficial ownership questions; Support FHFA reopening seasoned bulk transactions window; Comments to CFPB on Docket No. CFPB-2023- 0016 supporting trial disclosure waiver template application; Comments to CFPB on Docket No. CFPB-2022-0024 supporting registration of agency and court orders and requesting greater CFPB supervision of nonbank entities

Bank On Buy Now, Pay Later Central Bank Digital Currency Cryptocurrency Digital Assets Nominations USPS Pilot Banking Program H.R. 1996, The SAFE Banking Act H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 758, Promoting Access to Capital in Underbanked Communities Act of 2023 S. 910, SAFE Banking Act S.J.RES.15, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of Currency relating to "National Banks and Federal Savings Associations as Lenders." H.R.1533, Promoting New and Diverse Depository Institutions Act H.R. 6145, Community Bank Relief Act of 2021 S. 3409, To amend the Economic Growth, Regulatory Relief, and Consumer Protection Act 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. Emergency Capital Investment Issues for CDFI and MDI S. 3715, The E-SIGN Modernization Act Coin Circulation H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. H.R. 4277, Overdraft Protection Act of 2021 H.R 4521, America Competes Act of 2022 H.R.7003, Expanding Financial Access for Underserved Communities Act S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on Banking. UDAAP Supervisory Policies and Adjudication Procedures Issues impacting the modernization of the Community Reinvestment Act Deposit Insurance Assessment Rates S.4674, Credit Card Competition Act H.R. 8874, Credit Card Competition Act S.4760, Digital Commodities Consumer Protection Act of 2022 Merchant Category Codes

S 293 Fair Access to Banking Act 2023 S 245 Financial Institution Customer Protection Act 2023 S 817/HR 1602 SVB Act HR 1663 Critical Bank Review Act HR 758 Promoting Access to Capital in Underbanked Communities Act of 2023 S 362 TAILOR Act of 2023 S 583 FDIC Act of 2023 HR 556 21st Century Dollar Act S 293 Fair Access to Banking Act HR 1810 Bank Privacy Act HR 1409 FDIC Accountability Act HR 1533 Promoting New and Diverse Depository Institutions Act HR 1313 Transparency in CFPB Cost-Benefit Analysis HR 1411 Inspector General Reform Act of 2023 HR 2489 Amend and Update the CFPB S 915 Creation of an Inspector General of the Board of Governors of the Federal Reserve System HR 1410 Consumer Financial Protection Commission Act HR 500 Financial Exploitation Prevention Act of 2023 HR 802 Respect State Housing Laws Act HR 1382 TABS Act of 2023 Issues related to banking, payments, and lending

Client expense: $650,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), SENATE, Treasury, Dept of