CDFI Fund Transparency Act

H.R. 758 Promoting Access to Capital in Underbanked Communities Act of 2023 H.R. 1806 Small LENDER Act H.R. 1810 Bank Loan Privacy Act H.R. 2656 Trigger Leads Abatement Act H.R. 2891 SAFER Banking Act of 2023 H.R. 3161 CDFI Fund Transparency Act H.R. 3881 Credit Card Competition Act of 2023 H.R. 4766 Clarity for Payment Stablecoins Act of 2023 H.R. 5403 CBDC Anti-Surveillance State Act H.R. 6789 Rectifying Undefined Descriptions of Abusive Act and Practices Act H.R. 7297 Homebuyers Privacy Protection Act H.R. 7420 Ensuring Diversity in Community Banking Act H.R. 7483 Expanding Opportunity for MDIs Act H.R. 7531 Secure Payments Act HR 7890 Amendment in the Nature of a Substitute - American Privacy Rights Act H.R. 8818 American Privacy Rights Act HR 9303 Protecting Consumers from Payment Scams Act S. 1323 SAFE Banking Act of 2023 S. 1838 Credit Card Competition Act of 2023; Durbin Amendment on Debit Card Routing; Extension to Credit Cards S. 2860 SAFER Banking Act S. 3502 Homeowners Privacy Protection Act (Trigger Leads) S. 3538 Close the Shadow Banking Loophole Act S. 3801 CBDC Anti-Surveillance State Act S. 4155 Lummis -Gillibrand Payment Stablecoin Act S. 4570 Secure Payments Act S. 4638 National Defense Authorization Act for Fiscal Year 2025 S. 4943 Protecting Consumers from Payment Scams Act Senate Amendment 2358 to National Defense Authorization Act (Trigger Leads) Senate Amendment 3290 National Defense Authorization Act (Trigger leads) Anti-money laundering regulation - digital assets Artificial Intelligence Bank Merger Competitive Review Guidelines Bank-fintech partnerships Beneficial Ownership Cannabis Banking Central Bank Digital Currency Check Fraud Community Bank Access to Capital Community Development Financial Institutions Certification Community Reinvestment Act Credit Card Routing Mandates Credit Reporting Credit Union Acquisitions of Community Banks Credit Union Business Lending Powers Credit Union Field of Membership Rules Data Privacy De Novo Bank Formation Debit Card Interchange Fees and Routing Digital Assets Regulation EGRPRA Review FHFA Capital Rules Flood Insurance Implementation of Dodd Frank Act Section 1071 Implementation issues with the Anti-Money Laundering Act of 2020 Industrial Loan Company Charter Policy Instant Payments NSF and Overdraft Fees Open Banking / Dodd-Frank Section 1033 Opposing the SBAs proposal to repeal the moratorium on the number of Small Business Lending Companies (SBLC) that are permitted to make 7(a) loans. Payments Fraud Request for hearing on unfair Credit Union Competition Request that the CFPBs FCRA Rulemaking Process be Subject to an Advanced Notice of Proposed Rulemaking (ANPR) before it Publishes a Notice of Proposed Rulemaking (NPRM) SBA Direct 7(a) Direct Lending

Client expense: $736,305 · Firm income: Not reported

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

The Veteran Member Business Loan Act (S. 539/H.R. 4867) would exempt loans made to veteran-owned businesses from the credit union member business lending cap. The Credit Card Competition Act (S. 1838/H.R. 3881) would weaken the security of the credit card payments network through regulating the credit card interchange market. The CDFI Fund Transparency Act (H.R. 3161) would increase awareness of the CDFI application process. The CFPB-IG Reform Act (H.R. 1411/S. 915) would require a Senate-confirmed Inspector General to help oversee the CFPB. H.R. 1382, the TABS Act, would bring the CFPB under the traditional congressional appropriations process. H.R. 1410 (the Consumer Financial Protection Commission Act) would establish a five-member Board of Directors for the CFPB. HR 7531, the Secure Payments Act, would prevent finalization of the Federal Reserve's proposal to cap debit card interchange fees until a study is conducted on the impact to financial services, consumers, and financial institutions.

Client expense: $15,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), SENATE

H.R. 448, Putting Investors First Act of 2023 H.R. 758, Promoting Access to Capital in Underbanked Communities Act of 2023 H.R. 835, Fair Investment Opportunities for Professional Experts Act H.R. 1010/S. 453, Prohibiting IRS Financial Surveillance Act H.R. 1410, Consumer Financial Protection Commission Act H.R. 1548, Improving Access to Small Business Information Act H.R. 1553, Helping Angels Lead our Startups (HALOS) Act H.R. 1579, Accredited Investor Definition Review Act H.R. 2608, To amend the Federal securities laws to specify the periods for which financial statements are required to be provided by an emerging growth company, and for other purposes H.R. 2610, To amend the Securities Exchange Act of 1934 to specify certain registration statement contents for emerging growth companies, to permit issuers to file draft registration statements with the Securities and Exchange Commission for confidential review, and for other purposes H.R. 2612, Gig Worker Equity Compensation Act H.R. 2627, Increasing Investor Opportunities Act H.R. 2652, Investment Opportunity Expansion Act H.R. 2792, Small Entity Update Act H.R. 2793, Encouraging Public Offerings Act of 2023 H.R. 2795, Enhancing Multi-Class Share Disclosures Act H.R. 2796, Promoting Opportunities for Non-Traditional Capital Formation Act H.R. 2797, Equal Opportunity for All Investors Act H.R. 2798, CFPB Transparency and Accountability Reform Act H.R. 2799/S. 3815, Expanding Access to Capital Act of 2023 H.R. 2812, Middle Market IPO Underwriting Cost Act H.R. 3063, Retirement Fairness for Charities and Educational Institutions Act H.R. 3161, CDFI Fund Transparency Act H.R. 4035, Protecting Small Business Information Act of 2023 H.R. 4168/S. 2005, Mandatory Materiality Requirement Act of 2023 H.R. 4177/S. 2007, Improving Corporate Governance Through Diversity Act of 2023 H.R. 4366, Consolidated Appropriations Act, 2024, including provisions related to Senate Amendment 1217 and Senate Amendments 1092 H.R. 4664/S. 2309, Making appropriations for financial services and general government for the fiscal year ending September 30, 2024, and for other purposes H.R. 4790, Prioritizing Economic Growth Over Woke Policies Act H.R. 4823, American Financial Institution Regulator Sovereignty and Transparency Act H.R. 5488/S. 2805, Protecting Our Courts from Foreign Manipulation Act of 2023 H.R. 7000/S. 3592, Business of Insurance Regulatory Reform Act of 2024 H.R. 7092/S. 3676, Protecting Private Job Creators Act H.R. 7470/S.3823, Secure U.S. Leadership in Space Act of 2024 H.R. 8337, Bank Resilience and Regulatory Improvement Act H.R. 8338, Clarity in Lending Act H.R. 8339, SEC Reform and Restructuring Act H.R. 8773, Financial Services and General Government Appropriations Act, 2025 S. 638, Disclosure of Tax Havens and Offshoring Act S. 3541, Fair Audits and Inspections for Regulators Exams Act S. 5139, Empowering Main Street in America Act of 2024 H.J.Res. 100/S.J.Res. 50, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Securities and Exchange Commission relating to "Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure" H.J.Res. 120, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Financial Stability Oversight Council related to "Guidance on Nonbank Financial Company Determinations" H.J.Res. 122/H.J.Res.121/S.J.Res.70, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to "Credit Card Penalty Fees (Regulation Z)" H.J.Res. 201, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to "Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders" Potential legislation similar to H.R. 5598, Access to Small Business Investor Capital Act Potential legislation similar to H.R. 2025/S. 840, Litigation Funding Transparency Act SEC Proposed Rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors (87 Fed. Reg. 21,334-21,473, April 11, 2022) Proposed Rule, Securities and Exchange Commission; Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting (87 Fed. Reg. 77,172-77,296, December 16, 2022) Proposed Rule, Public Company Accounting Oversight Board; Amendments to Reporting Requirements for Registered Firms (PCAOB Release No. 2024-003, April 9, 2024; PCAOB Rulemaking Docket Matter No. 055) Proposed Rule, Public Company Accounting Oversight Board; Amendments to False or Misleading Statements Concerning PCAOB Registration and Oversight and Constructive Requests to Withdraw from Registration (PCAOB Release No. 2024-001, February 27, 2024; PCAOB Rulemaking Docket Matter No. 054) Proposed Rule, Public Company Accounting Oversight Board; Amendments to Firm and Engagement Metrics (PCAOB Release No. 2024-002, April 9, 2024; PCAOB Rulemaking Docket Matter No. 041) Adopting Order of the Securities and Exchange Commission: Public Company Accounting Oversight Board Amendments to QC 1000, A Firms System of Quality Control and Related Amendments to PCAOB Standards, Rules, and Forms (SEC Release No 34-100968; PCAOB File No. PCAOB-2024-002) Request for Information, U.S. Treasury, Uses, Opportunities, and Risks of Artificial Intelligence in the Financial Services Sector (TREAS-DO-2024-0011, June 12, 2024) Request for Comment, Commodity Futures Trading Commission (CFTC), The Use of Artificial Intelligence (AI) in CFTC-regulated derivatives markets (Fed. Reg. 89, 65,606, August 12, 2024) Final Rule, Security Exchange Commission, on Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure (88 Fed. Reg. 51,896-51,945, September 5, 2023) Proposed Rule, Security Exchange Commission, on Changes to 14a-8 (87 Fed. Reg. 45,052-45,075, July 27, 2022) Final Rule, Security Exchange Commission, on Share Repurchase Disclosure Modernization (88 Fed. Reg. 36,002-36,063, July 31, 2023) Proposed Rule, Securities and Exchange Commission, Enhanced Disclosures by Certain Investment Advisers and Investment Companies About Environmental, Social, and Governance Investment Practices (87 Fed. Reg. 63,016-63,017, October 18, 2022) Proposed Rule, Securities and Exchange Commission, Outsourcing by Investment Advisers (87 Fed. Reg. 68,816-68,883, November 16, 2022) Proposed Rule, Securities and Exchange Commission; Conflicts of Interest Associated with the Use of Predictive Data Analytics by Broker-Dealers and Investment Advisers (88 Fed. Reg. 53,960- 54,024, August 9, 2023) Proposed Rule, Security Exchange Commission, on Private Fund Advisers (87 FR 16,886, February 9, 2022) Proposed Rule, Security Exchange Commission, on Safeguarding Advisory Client Assets (88 Fed. Reg 14,672-14,792, March 9, 2023) Proposed Rule, Public Company Accounting Oversight Board; Amendments to PCAOB Auditing Standards related to a Companys Noncompliance with Laws and Regulations (PCAOB Release No. 2023-003/PCAOB Rulemaking Docket Matter No. 051, June 6, 2023) Various issues relating to SEC Best Interest and Enhancing Investment Adviser Regulation relating to broker-dealers, registered investment advisers, conflicts of interest; potential federal preemption of state fiduciary standards; CFTCs de minimis Exception for Swap Dealers; Securities and Exchange Commission amendments to the Commissioners whistleblower rules file no. S7-16-18; proxy process, proxy advisory firms, and other related aspects of corporate governance; corporate common ownership; adoption of the current expected credit loss (CECL) accounting standard; role of credit reporting agencies (CRAs) in the U.S. economy; debt collection practices (regulation F) under the Fair Debt Collection Practices Act (P.L. 95-109); qualified mortgage definition under the Truth in Lending Act (P.L. 90-321) (Regulation Z); Financial Stability Oversight Council activities, including the approach to and designation of systemic importance and risk of nonbank financial companies and firms; Federal Reserve Systems Large Institution Supervision Coordinating Committee; potential housing finance reform legislation; enforcement of Securities and Exchange Commission penalties; federal interest rate authority; Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) reform; electronic consent-based SSN Verification Service (eCBSV); environmental, social, and governance (ESG) enforcement; information collection under the Community Reinvestment Act (CRA) (P.L. 95-128); potential Financial Transaction Tax (FTT); potential Treasury Department proposal relating to tax reporting by banks; investment company cross trading; potential money market fund reform measures; transition to the secured overnight financing rate; implementation of SEC Rule 15c2-11; Department of Labor fiduciary advice exemption: PTE 2020-02; benefits of risk-based pricing; mobile disclosures; modernization of the Credit Repair Organizations Act (enacted as Title IV of the Consumer Credit Protection Act, P.L. 90-321); Internal Revenue Service Priority Guidance Plan; Financial Accounting Standards Board improvements to income tax disclosures; climate-related financial risk management for large banks; Consumer Financial Protection Bureau (CFPB) regulatory sandbox for disclosures; CFPB Policy Fellowship program; CFPB amendment of its Supervision and Examination Manual; CFPB conflation of Distinct Statutory Concepts of Unfairness and Discrimination; CFPB Small Business Advisory Review Panels Rulemaking on Personal Financial Data Rights; CFPB implementation of the Small Business Lending Data Collection Rule (the 1071 Rule); SEC Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting (File Number S7-26-22); Federal Deposit Insurance Corporation Proposal on Corporate Governance and Risk Management; Basel III Endgame Rule; FDIC Monitoring of Investment Funds Passivity Agreements; issues related to the Export-Import Bank of the United States; European Commission debates over stricter rules on third-party delegation; European Union Capital Markets Union; retail participation in capital markets; United Kingdom pensions reform; European Unions Corporate Sustainability Due Diligence Directive (CSDDD); EU sustainable finance action plan and incorporating ESG factors into financial services; reporting metrics of American companies under the EUs Corporate Sustainability Reporting Directive and Corporate Sustainability Due Diligence Directive; reporting metrics of American companies under the California climate disclosure laws; reporting metrics of American companies on diversity, equity, and inclusion; reporting metrics of American companies on executive compensation; reporting metrics for private companies under Securities and Exchange Commission rules; reform to the function of the Public Company Accounting Oversight Board; interconnectedness of the SECs rulemaking agenda; potential rulemaking regarding Section 956 of the Dodd-Frank Act (P.L. 111-203); SEC Staff Report Review of the Accredited Investor Definition under the Dodd Frank Act; index fund passivity; oversight issues and potential legislation on third party litigation funding (including its national security implications)

H.R. 758, Promoting Access to Capital in Underbanked Communities Act of 2023 H.R. 3161, CDFI Fund Transparency Act H.R. 4035, Protecting Small Business Information Act 2023 H.R. 8070, Servicemember Quality of Life Improvement and National Defense Authorization Act for Fiscal Year 2025 H.R. 8337, Bank Resilience and Regulatory Improvement Act H.R. 8338, Clarity in Lending Act H.R. 8773, Financial Services and General Government Appropriations Act, 2025 S. 3541, Fair Audits and Inspections for Regulators Exams Act H.J.Res. 122/S.J.Res. 70, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to "Credit Card Penalty Fees (Regulation Z)" H.J.Res. 201, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to "Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders" Proposed Rule, Consumer Financial Protection Bureau; Registry of Supervised Nonbanks that Use Form Contracts to Impose Terms and Conditions that Seek to Waive or Limit Consumer Legal Protections (88 Fed. Reg. 6,906-6,969, February 1, 2023) Proposed Rule, Consumer Financial Protection Bureau; Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders (88 Fed. Reg. 6,088-6,142, January 30, 2023) Proposed Rule, Consumer Financial Protection Bureau; Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications (88 Fed. Reg. 80,197-80,216, November 17, 2023) Proposed Rule, Consumer Financial Protection Bureau; Overdraft Lending: Very Large Financial Institutions (89 Fed. Reg. 13,852-13,908, February 23, 2024) Proposed Rule, Consumer Financial Protection Bureau; Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information (Regulation V) (89 Fed Reg. 51,682-51,736, June 18, 2024) Proposed Rule, Consumer Financial Protection Bureau; Fees for Instantaneously Declined Transactions (89 Fed. Reg. 6,031-6,051, March 25, 2024) Consumer Financial Protection Bureau; Agency Information Collection Activities: Comment Request (89 Fed. Reg. 4,281-4,282, January 23, 2024) Proposed Rule, Federal Deposit Insurance Corporation, Statement of Policy on Bank Merger Transactions (89 Fed. Reg. 29,222-29,244, June 18, 2024) Interpretive Rule, Truth in Lending (Regulation Z); Use of Digital User Accounts To Access Buy Now, Pay Later Loans (89. Fed. Reg. 47,068-47,073, May 31, 2024) Interpretive Rule, Truth in Lending (Regulation z); Consumer Credit Offered to Borrowers in Advance of Expected Receipt of Compensation for Work (89 Fed. Reg. 61,358-61,363, July 31, 2024) Various issues relating to the Consumer Financial Protection Bureaus Advisory Opinion regarding section 1034(c) of the Consumer Financial Protection Act (CFPA) published on October 11, 2023; Regulatory Capital Rules: Regulatory Capital, Implementation of Basel III, Capital Adequacy, Transition Provisions, Prompt Corrective Action, Standardized Approach for Risk-weighted Assets, Market Discipline and Disclosure Requirements, Advanced Approaches Risk-Based Capital Rule, and Market Risk Capital Rule; outline of proposals under consideration and alternatives considered, Consumer Financial Protection Bureau, rulemaking under the Fair Credit Reporting Act, published on September 15, 2023; rulemaking petition filed with the Consumer Financial Protection Bureau To Require Meaningful Consumer Consent Regarding the Use of Arbitration to Resolve Disputes Involving Consumer Financial Products and Services; potential rulemaking regarding Section 956 of the Dodd-Frank Act (P.L. 111-203)

Work to keep insurance regulated by the states and not by the Consumer Financial Protection Bureau or set by international bodies. Oppose legislation to repeal the McCarran-Ferguson antitrust exemption for the business of insurance. Advocate for privacy measures in line with GLBA and HIPAA as applied to financial services. Support H.R. 1165, the Data Privacy Act introduced by HFSC Chairman McHenry. Oppose H.R. 8818, the American Privacy Rights Act, which contains a private right of action and does not include federal preemption or an exemption for GLBA. Support legislation of e-signatures, e-disclosures, and e-notarizations, including E-Sign Modernization Act. Support H.R.1059, SECURE Notarization Act. Support S. 869, the CDFI Bond Guarantee Program Improve Act. Support H.R. 3161, the CDFI Fund Transparency Act, which would require the Fund's Director to testify annually before the HFS and SB Committees. Support increased CDFI and MDI funding in President's FY 2024 Budget Proposal and House Appropriations FSSC Bill. Support H.R. 2891/S. 1323/S. 2860, the Secure and Fair Enforcement Banking SAFE Act and Secure and Fair Enforcement Regulation Banking (SAFER) Act. This bill generally prohibits a federal regulator from penalizing a financial institution for providing services to a legitimate cannabis-related business. Oppose H.R. 3881/S. 1838, the Credit Card Competition Act, a bill that would reduce interchange fees on credit cards. Support H.R. 1807, Improving Disclosure for Investors Act of 2023, to provide electronic delivery of SEC regulatory documents. Included in H.R. 2799, Expanding Access to Capital Act. Support H.R. 500, Financial Exploitation Prevention Act. H.R. 7036, Strengthening Cyber Security for the Financial Sector Act. Working to exclude the "business of insurance" from NCUA's third party vendor bill, keeping insurance regulated by the states. Support H.R. 7440, Financial Services Innovation Act, which develops regulatory pathways for facilitating responsible innovation in fintech. Support H.R. 9767, the Promoting and Advancing Communities of Color Through Inclusive Lending Act. Oppose H.R. 9303, the Protecting Consumers from Payment Scams Act, which would change EFTA's definition of an unauthorized transfer to cover fraudulently induced transactions

The Veteran Member Business Loan Act (S. 539/H.R. 4867) would exempt loans made to veteran-owned businesses from the credit union member business lending cap. The Credit Card Competition Act (S. 1838/H.R. 3881) would weaken the security of the credit card payments network through regulating the credit card interchange market. The CDFI Fund Transparency Act (H.R. 3161) would increase awareness of the CDFI application process. The CFPB-IG Reform Act (H.R. 1411/S. 915) would require a Senate-confirmed Inspector General to help oversee the CFPB. H.R. 1382, the TABS Act, would bring the CFPB under the traditional congressional appropriations process. H.R. 1410 (the Consumer Financial Protection Commission Act) would establish a five-member Board of Directors for the CFPB. HR 7531, the Secure Payments Act, would prevent finalization of the Federal Reserve's proposal to cap debit card interchange fees until a study is conducted on the impact to financial services, consumers, and financial institutions.

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

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), SENATE

The Veteran Member Business Loan Act (S. 539/H.R. 4867) would exempt loans made to veteran-owned businesses from the credit union member business lending cap. The Credit Card Competition Act (S. 1838/H.R. 3881) would weaken the security of the credit card payments network through regulating the credit card interchange market. The CDFI Fund Transparency Act (H.R. 3161) would increase awareness of the CDFI application process. The CFPB-IG Reform Act (H.R. 1411/S. 915) would require a Senate-confirmed Inspector General to help oversee the CFPB. H.R. 1382, the TABS Act, would bring the CFPB under the traditional congressional appropriations process. H.R. 1410 (the Consumer Financial Protection Commission Act) would establish a five-member Board of Directors for the CFPB. HR 7531, the Secure Payments Act, would prevent finalization of the Federal Reserve's proposal to cap debit card interchange fees until a study is conducted on the impact to financial services, consumers, and financial institutions.

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

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), SENATE

Credit Union Loan Maturity Issues Credit Union Field of Membership issues S. 539 - Veterans Member Business Loan Act H.R. 4867 - Veterans Member Business Loan Act Issues related to housing Finance Reform Financial Services Regulatory Relief issues Issues related to consumer financial protection Issues related to Digital Assets Credit Union Tax Status Issues related to National Credit Union Administration Examination Procedures Proposed new tax reporting requirements for financial institutions Foreign Account Tax Compliance Act Issues related Credit Card Late Fee Rule H.R. 4868, the Member Business Loan Expansion Act S. 3992, Protecting Access to Credit for Small Businesses Act H.R. 6933, the Expanding Access to Lending Options Act H.R. 3161, the CDFI Fund Transparency Act H.R. 7338, the Rural Credit Access Act of 2024 Issues related to changes to NCUA call report re overdraft/non-sufficient funds fee disclosures Issues related to Overseas Military Banking Program Issues related to Greenhouse Gas Reduction Fund Issues related to CFPB Junk Fees Regulations Issues related to Federal Home Loan Banks Issues related to Overdraft and Non-sufficient Funds Fees Issues related to Fair Lending Issues related to credit union conversions Issues related to Financial inclusion H.J.Res. 122 - Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to "Credit Card Penalty Fees (Regulation Z) H.R. 7036 Strengthening Cybersecurity for the Financial Sector Act H.R. 7000; S. 3592 Business of Insurance Regulatory Reform Act EPA Greenhouse Gas Reduction Fund Issues related to flood insurance Support regulator- and bank-approved credit union-bank mergers Support assistance for MDI credit unions Oppose CRA requirements for credit unions Support FCU Act modernization Support expanded credit union investment authority Support expanded credit union examination cycle Support increased examination transparency Support Central Liquidity Facility enhancements Support parity for credit unions related to stablecoin regulation Support mandatory arbitration agreements Oppose national interest rate cap Support reduced GSE costs for credit union mortgages Support secondary mortgage market access for credit unions Support making CFPB subject to regular appropriations process Support restructuring CFPB leadership to a bipartisan commission Support increasing asset thresholds for CFPB supervision Support clarification of CFPB UDAAP authority Support CFPB use of Section 1022 authority to exempt credit unions from certain regulations Support CFPB oversight and monitoring of nonbank entities Oppose CFPB efforts to avoid requirements of the rulemaking process Support CFPB use and disclosure of relevant data in rulemakings Support CFPB policies to promote innovation and access to credit Support CFPB coordination with NCUA on policy matters and examination scheduling Oppose arbitrary limits on credit union fee income Support holistic evaluation of regulatory burden on credit unions Oppose expansion of Regulation E financial institution liability; Support fair distribution of Regulation E error resolution responsibilities Oppose Regulation E liability for financial institutions for consumer-authorized transactions Oppose nominal leases for banks on military installations Oppose development of a CBDC Support credit union access to Federal Reserve liquidity options Oppose proposed CFPB auto lending data collection Support FinCEN implementation of the Corporate Transparency Act Support exemptions for CFPB Section 1071 final rule Oppose legislative action on the Overseas Military Banking Program Oppose credit union-related amendments to the FY 2025 NDAA Support federal share insurance for all credit unions acting as fiscal agents of the U.S. government Oppose CFPB proposed rule on overdraft for very large financial institutions Oppose CFPB efforts to restrict information in credit reports Oppose Credit Card Competition Act (H.R. 3881, S. 1838) Support SAFE Banking Act (H.R. 2891; S. 1323) Support SAFER Banking Act (S. 2860) Oppose Capping Credit Card Interest Rates Act (S. 2760) Support Close the Shadow Banking Loophole Act (S. 3538) Support CBDC Anti-Surveillance State Act (H.R. 5403; S. 3801) Support Consumer Financial Protection Commission Act (H.R. 1410) Support CFPB Transparency and Accountability Reform Act (H.R. 2798) Support FAIR Exams Act (H.R. 8071) Support Credit Union Board Modernization Act (H.R. 582, S. 610) Support Secure Payments Act (H.R. 7531; S. 4570) Support Consumer Financial Protection Bureau Accountability Act (S. 4521) Oppose American Privacy Rights Act (H.R. 8818) Oppose CFPB Section 1071 final rule Oppose CFPB Section 1033 proposed rule Support NCUA action to permit credit union reimbursement of childcare expenses for FCU board meetings Support modification of FHFA first-generation homebuyer definition

H.R. 758, Promoting Access to Capital in Underbanked Communities Act of 2023 H.R. 3161, CDFI Fund Transparency Act H.R. 4035, Protecting Small Business Information Act 2023 H.R. 8070, Servicemember Quality of Life Improvement and National Defense Authorization Act for Fiscal Year 2025 H.R. 8337, Bank Resilience and Regulatory Improvement Act H.R. 8338, Clarity in Lending Act H.R. 8773, Financial Services and General Government Appropriations Act, 2025 S. 3541, Fair Audits and Inspections for Regulators Exams Act H.J.Res. 122/S.J.Res. 70, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to "Credit Card Penalty Fees (Regulation Z)" Proposed Rule, Consumer Financial Protection Bureau; Registry of Supervised Nonbanks that Use Form Contracts to Impose Terms and Conditions that Seek to Waive or Limit Consumer Legal Protections (88 Fed. Reg. 6,906-6,969, February 1, 2023) Proposed Rule, Consumer Financial Protection Bureau; Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders (88 Fed. Reg. 6,088-6,142, January 30, 2023) Proposed Rule, Consumer Financial Protection Bureau; Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications (88 Fed. Reg. 80,197-80,216, November 17, 2023) Proposed Rule, Consumer Financial Protection Bureau; Overdraft Lending: Very Large Financial Institutions (89 Fed. Reg. 13,852-13,908, February 23, 2024) Proposed Rule, Consumer Financial Protection Bureau; Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information (Regulation V) (89 Fed Reg. 51,682-51,736, June 18, 2024) Proposed Rule, Consumer Financial Protection Bureau; Fees for Instantaneously Declined Transactions (89 Fed. Reg. 6,031-6,051, March 25, 2024) Consumer Financial Protection Bureau; Agency Information Collection Activities: Comment Request (89 Fed. Reg. 4,281-4,282, January 23, 2024) Proposed Rule, Federal Deposit Insurance Corporation, Statement of Policy on Bank Merger Transactions (89 Fed. Reg. 29,222-29,244, June 18, 2024) Various issues relating to the Consumer Financial Protection Bureaus Advisory Opinion regarding section 1034(c) of the Consumer Financial Protection Act (CFPA) published on October 11, 2023; Regulatory Capital Rules: Regulatory Capital, Implementation of Basel III, Capital Adequacy, Transition Provisions, Prompt Corrective Action, Standardized Approach for Risk-weighted Assets, Market Discipline and Disclosure Requirements, Advanced Approaches Risk-Based Capital Rule, and Market Risk Capital Rule; outline of proposals under consideration and alternatives considered, Consumer Financial Protection Bureau, rulemaking under the Fair Credit Reporting Act, published on September 15, 2023; rulemaking petition filed with the Consumer Financial Protection Bureau To Require Meaningful Consumer Consent Regarding the Use of Arbitration to Resolve Disputes Involving Consumer Financial Products and Services; potential rulemaking regarding Section 956 of the Dodd-Frank Act (P.L. 111-203)

H.R. 448, Putting Investors First Act of 2023 H.R. 758, Promoting Access to Capital in Underbanked Communities Act of 2023 H.R. 835, Fair Investment Opportunities for Professional Experts Act H.R. 1010/S. 453, Prohibiting IRS Financial Surveillance Act H.R. 1410, Consumer Financial Protection Commission Act H.R. 1548, Improving Access to Small Business Information Act H.R. 1553, Helping Angels Lead our Startups (HALOS) Act H.R. 1579, Accredited Investor Definition Review Act H.R. 2608, To amend the Federal securities laws to specify the periods for which financial statements are required to be provided by an emerging growth company, and for other purposes H.R. 2610, To amend the Securities Exchange Act of 1934 to specify certain registration statement contents for emerging growth companies, to permit issuers to file draft registration statements with the Securities and Exchange Commission for confidential review, and for other purposes H.R. 2612, Gig Worker Equity Compensation Act H.R. 2627, Increasing Investor Opportunities Act H.R. 2652, Investment Opportunity Expansion Act H.R. 2792, Small Entity Update Act H.R. 2793, Encouraging Public Offerings Act of 2023 H.R. 2795, Enhancing Multi-Class Share Disclosures Act H.R. 2796, Promoting Opportunities for Non-Traditional Capital Formation Act H.R. 2797, Equal Opportunity for All Investors Act H.R. 2798, CFPB Transparency and Accountability Reform Act H.R. 2799/S. 3815, Expanding Access to Capital Act of 2023 H.R. 2812, Middle Market IPO Underwriting Cost Act H.R. 3063, Retirement Fairness for Charities and Educational Institutions Act H.R. 3161, CDFI Fund Transparency Act H.R. 4035, Protecting Small Business Information Act of 2023 H.R. 4168/S. 2005, Mandatory Materiality Requirement Act of 2023 H.R. 4177/S. 2007, Improving Corporate Governance Through Diversity Act of 2023 H.R. 4366, Consolidated Appropriations Act, 2024, including provisions related to Senate Amendment 1217 and Senate Amendment 1092 H.R. 4664/S. 2309, Making appropriations for financial services and general government for the fiscal year ending September 30, 2024, and for other purposes H.R. 4823, American Financial Institution Regulator Sovereignty and Transparency Act H.R. 5488/S. 2805, Protecting Our Courts from Foreign Manipulation Act of 2023 H.R. 7000/S. 3592, Business of Insurance Regulatory Reform Act of 2024 H.R. 7092/S. 3676, Protecting Private Job Creators Act H.R. 7470/S.3823, Secure U.S. Leadership in Space Act of 2024 H.R. 8070, Service Member Quality of Life Improvement and National Defense Authorization for Fiscal Year 2025 H.R. 8337, Bank Resilience and Regulatory Improvement Act H.R. 8338, Clarity in Lending Act H.R. 8339, SEC Reform and Restructuring Act H.R. 8773, Financial Services and General Government Appropriations Act, 2025 S. 638, Disclosure of Tax Havens and Offshoring Act S. 3541, Fair Audits and Inspections for Regulators Exams Act H.J.Res. 100 / S.J.Res. 50, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Securities and Exchange Commission relating to "Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure" H.J.Res. 120, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Financial Stability Oversight Council related to "Guidance on Nonbank Financial Company Determinations" H.J.Res. 122/H.J.Res.121/S.J.Res.70, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to "Credit Card Penalty Fees (Regulation Z)" Draft legislation titled Accredited Investor Self-Certification Act Potential legislation on environmental, social, and governance issues Potential legislation to reform the Securities and Exchange Commission Potential legislation similar to H.R. 5598, Access to Small Business Investor Capital Act Potential legislation similar to H.R. 2025/S. 840, Litigation Funding Transparency Act SEC Proposed Rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors (87 Fed. Reg. 21,334-21,473, April 11, 2022) Proposed Rule, Securities and Exchange Commission; Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting (87 Fed. Reg. 77,172-77,296, December 16, 2022) Notice of Proposed Rulemaking, Internal Revenue Service (IRS), Treasury; Excise Tax on Repurchase of Corporate Stock-Procedure and Administration (89 Fed. Reg. 25,829-25,834, April 12, 2024) Notice of Proposed Rulemaking, Section 45V Credit for Production of Clean Hydrogen; Section 48(a)(15) Election To Treat Clean Hydrogen Production Facilities as Energy Property (89 Fed. Reg. 25,551-25,553, April 11, 2024) Proposed Rule, Public Company Accounting Oversight Board; Amendments to Reporting Requirements for Registered Firms (PCAOB Release No. 2024-003, April 9, 2024; PCAOB Rulemaking Docket Matter No. 055) Proposed Rule, Public Company Accounting Oversight Board; Amendments to False or Misleading Statements Concerning PCAOB Registration and Oversight and Constructive Requests to Withdraw from Registration (PCAOB Release No. 2024-001, February 27, 2024; PCAOB Rulemaking Docket Matter No. 054) Proposed Rule, Public Company Accounting Oversight Board; Amendments to Firm and Engagement Metrics (PCAOB Release No. 2024-002, April 9, 2024; PCAOB Rulemaking Docket Matter No. 041) Final Rule, Security Exchange Commission on Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure (88 Fed. Reg. 51,896-51,945, September 5, 2023) Proposed Rule, Security Exchange Commission on Changes to 14a-8 (87 Fed. Reg. 45,052-45,075, July 27, 2022) Proposed Rule, Consumer Financial Protection Bureau; Overdraft Lending: Very Large Financial Institutions (89 Fed. Reg. 13,852-13,908, February 23, 2024) Final Rule, Security Exchange Commission on Share Repurchase Disclosure Modernization (88 Fed. Reg. 36,002-36,063, July 31, 2023) Proposed Rule, FSOC Authority to Require Supervision and Regulation of Certain Nonbank Financial Companies, Proposed Interpretive Guidance (88 Fed. Reg. 26,234-26,244, April 28, 2023) Proposed Rule, FSOC Analytic Framework for Financial Stability Risk Identification, Assessment, and Response, Proposed Analytic Framework (88 Fed. Reg. 26,305-26,311, April 28, 2023) Proposed Rule, Securities and Exchange Commission; Conflicts of Interest Associated with the Use of Predictive Data Analytics by Broker-Dealers and Investment Advisers (88 Fed. Reg. 53,960- 54,024, August 9, 2023) Proposed Rule, Security Exchange Commission on Private Fund Advisers (87 FR 16,886, February 9, 2022) Proposed Rule, Security Exchange Commission on Safeguarding Advisory Client Assets (88 Fed. Reg 14,672-14,792, March 9, 2023) Proposed Rule, Federal Deposit Insurance Corporation; Request for Comment on Proposed Statement of Policy on Bank Merger Transactions (89 Fed. Reg. 29,222-29,244, April 19, 2024) Proposed Rule, Public Company Accounting Oversight Board; Amendments to PCAOB Auditing Standards related to a Companys Noncompliance with Laws and Regulations (PCAOB Release No. 2023-003/PCAOB Rulemaking Docket Matter No. 051, June 6, 2023) Notice and Request for Comment, Consumer Financial Protection Bureau; Agency Information Collection Activities (89 Fed. Reg 4,281-4,282, January 23, 2024) Proposed Rule, Consumer Financial Protection Bureau; Defining Larger Participants of a Market for General Use Digital Consumer Payment Applications (88 Fed. Reg. 80,197-80,216, November 17, 2023) Various issues relating to SEC Best Interest and Enhancing Investment Adviser Regulation relating to broker-dealers, registered investment advisers, conflicts of interest; potential federal preemption of state fiduciary standards; CFTCs de minimis Exception for Swap Dealers; Securities and Exchange Commission amendments to the Commissioners whistleblower rules file no. S7-16-18; proxy process, proxy advisory firms, and other related aspects of corporate governance corporate common ownership; adoption of the current expected credit loss (CECL) accounting standard; role of credit reporting agencies (CRAs) in the U.S. economy; debt collection practices (regulation F) under the Fair Debt Collection Practices Act (P.L. 95-109); qualified mortgage definition under the Truth in Lending Act (P.L. 90-321) (Regulation Z); Financial Stability Oversight Council activities, including the approach to and designation of systemic importance and risk of nonbank financial companies and firms; Federal Reserve Systems Large Institution Supervision Coordinating Committee; potential housing finance reform legislation; enforcement of Securities and Exchange Commission penalties; federal interest rate authority; Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) reform; electronic consent-based SSN Verification Service (eCBSV); environmental, social, and governance (ESG) enforcement; information collection under the Community Reinvestment Act (CRA) (P.L. 95-128); potential Financial Transaction Tax (FTT); potential Treasury Department proposal relating to tax reporting by banks; investment company cross trading; potential money market fund reform measures; transition to the secured overnight financing rate; implementation of SEC Rule 15c2-11; Department of Labor fiduciary advice exemption: PTE 2020-02; benefits of risk-based pricing; mobile disclosures; modernization of the Credit Repair Organizations Act (enacted as Title IV of the Consumer Credit Protection Act, P.L. 90-321); Internal Revenue Service Priority Guidance Plan; Federal Trade Commission issues: Freedom of Information Act Requests, Penalty Offense Authority, Zombie Voting, and overall direction of the Commission under Chair Lina Khan; Financial Accounting Standards Board improvements to income tax disclosures; Climate-Related Financial Risk Management for Large Banks; CFPB regulatory sandbox for disclosures; CFPB Policy Fellowship program; CFPB amendment of its Supervision and Examination Manual; CFPB conflation of Distinct Statutory Concepts of Unfairness and Discrimination; CFPB Small Business Advisory Review Panels Rulemaking on Personal Financial Data Rights; CFPB implementation of the Small Business Lending Data Collection Rule (the 1071 Rule); SEC Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting (File Number S7-26-22); Federal Deposit Insurance Corporation Proposal on Corporate Governance and Risk Management; Basel III Endgame Rule; FDIC Monitoring of Investment Funds Passivity Agreements; issues related to the Export-Import Bank of the United States; EU sustainable finance action plan and incorporating ESG factors into financial services; reporting metrics of American companies under the EUs Corporate Sustainability Reporting Directive and Corporate Sustainability Due Diligence Directive; reporting metrics of American companies under the California climate disclosure laws; interconnectedness of the SECs rulemaking agenda; potential rulemaking regarding Section 956 of the Dodd-Frank Act (P.L. 111-203); SEC Staff Report Review of the Accredited Investor Definition under the Dodd Frank Act index fund passivity; oversight issues and potential legislation on third party litigation funding (including its national security implications)

H.R. 758 Promoting Access to Capital in Underbanked Communities Act of 2023 H.R. 1165 Financial Data Privacy Act of 2023 H.R. 1806 Small LENDER Act H.R. 1810 Bank Loan Privacy Act H.R. 2656 Trigger Leads Abatement Act H.R. 2891 SAFER Banking Act of 2023 H.R. 3161 CDFI Fund Transparency Act H.R. 3881 Credit Card Competition Act of 2023 H.R. 4035 Protecting Small Business Information Act of 2023 H.R. 4198 To amend section 604(c) of the Fair Credit Reporting Act to address the treatment of pre-screening report requests, and for other purposes. H.R. 4346 Small Bank Holding Company Relief Act H.R. 4766 Clarity for Payment Stablecoins Act of 2023 H.R. 5403 CBDC Anti-Surveillance State Act H.R. 6398 Financial Institution Regulatory Tailoring Enhancement Act H.R. 6789 Rectifying Undefined Descriptions of Abusive Act and Practices Act H.R. 7297 Homebuyers Privacy Protection Act H.R. 7420 Ensuring Diversity in Community Banking Act H.R. 7483 Expanding Opportunity for MDIs Act H.R. 7531 Secure Payments Act H.R. 8152 American Data Privacy and Protection Act H.R. 8264 Bank Supervision Appeals Improvement Act H.R. 8337 Bank Resilience and Regulatory Improvement Act H.R. 8338 Clarity in Lending Act H.R. 8818 American Privacy Rights Act H.J. Res 122 Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to "Credit Card Penalty Fees (Regulation Z)". S. 1323 SAFE Banking Act of 2023 S. 1838 Credit Card Competition Act of 2023; Durbin Amendment on Debit Card Routing; Extension to Credit Cards S. 2281 Lummis-Gillibrand Responsible Financial Innovation Act S. 2860 SAFER Banking Act S. 3502 Homeowners Privacy Protection Act (Trigger Leads) S. 3538 Close the Shadow Banking Loophole Act S. 3801 CBDC Anti-Surveillance State Act S. 4155 Lummis -Gillibrand Payment Stablecoin Act S. 4570 Secure Payments Act S.J. Res 70 Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to "Credit Card Penalty Fees (Regulation Z) Anti-money laundering regulation - digital assets Artificial Intelligence Bank Merger Competitive Review Guidelines Bank-fintech partnerships Beneficial Ownership Cannabis Banking Central Bank Digital Currency Check Fraud Climate Risk Disclosure Requirements Climate Related Financial Regulation Community Bank Access to Capital Community Development Financial Institutions Certification Community Reinvestment Act Credit Card Routing Mandates Credit Reporting Credit Union Acquisitions of Community Banks Credit Union Business Lending Powers Credit Union Field of Membership Rules Crypto Assets, Decentralized Finance, and Central Bank Digital Currency Cryptocurrency Regulation Data Privacy De Novo Bank Formation Debit Card Interchange Fees and Routing Deposit insurance reform Digital Assets Regulation EGRPRA Review FHFA Capital Rules Flood Insurance Implementation of Dodd Frank Act Section 1071 Implementation issues with the Anti-Money Laundering Act of 2020 Industrial Loan Company Charter Policy Instant Payments Issues associated with the Federal Reserves discount window NSF and Overdraft Fees Open Banking / Dodd-Frank Section 1033 Opposing the SBAs proposal to repeal the moratorium on the number of Small Business Lending Companies (SBLC) that are permitted to make 7(a) loans. Request for hearing on unfair Credit Union Competition Request that the CFPBs FCRA Rulemaking Process be Subject to an Advanced Notice of Proposed Rulemaking (ANPR) before it Publishes a Notice of Proposed Rulemaking (NPRM) SBA Direct 7(a) Direct Lending Stablecoin, Crypto Currency Regulatory Policy

Work to keep insurance regulated by the states and not by the Consumer Financial Protection Bureau or set by international bodies. Oppose legislation to repeal the McCarran-Ferguson antitrust exemption for the business of insurance. Advocate for privacy measures in line with GLBA and HIPAA as applied to financial services. Support H.R. 1165, the Data Privacy Act introduced by HFSC Chairman McHenry. Oppose H.R. 8818, the American Privacy Rights Act, which contains a private right of action and does not include federal preemption or an exemption for GLBA. Support legislation of e-signatures, e-disclosures, and e-notarizations, including E-Sign Modernization Act. Support H.R.1059, SECURE Notarization Act. Support S. 869, the CDFI Bond Guarantee Program Improve Act. Support H.R. 3161, the CDFI Fund Transparency Act, which would require the Fund's Director to testify annually before the HFS and SB Committees. Support increased CDFI and MDI funding in President's FY 2024 Budget Proposal and House Appropriations FSSC Bill. Support H.R. 2891/S. 1323/S. 2860, the Secure and Fair Enforcement Banking SAFE Act and Secure and Fair Enforcement Regulation Banking (SAFER) Act. This bill generally prohibits a federal regulator from penalizing a financial institution for providing services to a legitimate cannabis-related business. Oppose H.R. 3881/S. 1838, the Credit Card Competition Act, a bill that would reduce interchange fees on credit cards. Support H.R. 1807, Improving Disclosure for Investors Act of 2023, to provide electronic delivery of SEC regulatory documents. Included in H.R. 2799, Expanding Access to Capital Act. Support H.R. 500, Financial Exploitation Prevention Act. H.R. 7036, Strengthening Cyber Security for the Financial Sector Act. Working to exclude the "business of insurance" from NCUA's third party vendor bill, keeping insurance regulated by the states. Support H.R. 7440, Financial Services Innovation Act, which develops regulatory pathways for facilitating responsible innovation in fintech.

Credit Card Interchange Fees - S. 1838 and H.R. 3881 - Credit Card Competition Act of 2023 Credit Union Loan Maturity Issues Issues related to access to financial services Credit Union Field of Membership issues Issues related to Credit Union Member Business Lending Caps S. 539 - Veterans Member Business Loan Act H.R. 4867 - Veterans Member Business Loan Act Issues related to housing Finance Reform Financial Services Regulatory Relief issues Issues related to Data Security and Data Privacy S. 610 - Credit Union Board Modernization Act S.2860 - Secure and Fair Enforcement Regulation Banking Act S. 1323 - Secure and Fair Enforcement Banking Act S. 2760 - Capping Credit Card Interest Rates Act S. 3538, Close the Shadow Banking Loophole Act Issues related to the National Defense Authorization Act Issues related to the Consumer Financial Protection Board Issues related to consumer financial protection Issues related to Community Development Financial Institutions Issues related to the Community Development Revolving Loan Fund Issues related to Credit Union Loan Maturities Issues related to Digital Assets Credit Union Tax Status Issues related to Financial Services Regulatory Relief Issues related to National Credit Union Administration Examination Procedures Proposed new tax reporting requirements for financial institutions Postal Banking Issues related to FinCEN and appropriations thereto Issues related to privately insured credit unions Issues related to the Federal Reserves new liquidity facility Issues related to the safety and soundness of credit unions Issues related to the Military Lending Act Issues related to regulation of Credit Unions as employers Issues related to Housing Finance Reform Issues related to management and operation of Credit Unions Issues related to Large Participants for General-Use Digital Consumer Payment Applications Foreign Account Tax Compliance Act Issues related to minority depository institutions Issues related to diversity, equity, and inclusion initiatives Issues related Credit Card Late Fee Rule H.R. 4868, the Member Business Loan Expansion Act S. 3992, Protecting Access to Credit for Small Businesses Act H.R. 6933, the Expanding Access to Lending Options Act H.R. 3161, the CDFI Fund Transparency Act H.R. 7338, the Rural Credit Access Act of 2024 Issues related to third party vendor authority Issues related to changes to NCUA call report re overdraft/non-sufficient funds fee disclosures Issues related to NCUA request for comment on climate-related financial risk Issues related to Overseas Military Banking Program Issues related to Greenhouse Gas Reduction Fund Issues related to CFPB Junk Fees Regulations Issues related to Federal Home Loan Banks Issues related to Overdraft and Non-sufficient Funds Fees Issues related to Fair Lending Issues related to premium assessments by the National Credit Union Share Insurance Fund Issues related to credit union conversions Issues related to capital reform for credit unions Issues related to Financial inclusion Issues related to Unfair, Deceptive, or Abusive acts or practices Issues related to Credit Union Fintech Investment Authority H.J.Res. 122 - Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to "Credit Card Penalty Fees (Regulation Z) H.R. 7440 Financial Services Innovation Act Issues related to AI in financial services H.R. 7036 Strengthening Cybersecurity for the Financial Sector Act H.R. 7000; S. 3592 Business of Insurance Regulatory Reform Act Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements EPA Greenhouse Gas Reduction Fund Issues related to flood insurance Issues related to Credit Union Service Organizations (CUSO)

Credit Card Interchange Fees - S. 1838 and H.R. 3881 - Credit Card Competition Act of 2023 Credit Union Loan Maturity Issues Issues related to access to financial services Credit Union Field of Membership issues Issues related to Credit Union Member Business Lending Caps S. 539 - Veterans Member Business Loan Act H.R. 4867 - Veterans Member Business Loan Act Issues related to housing Finance Reform Financial Services Regulatory Relief issues Issues related to Data Security and Data Privacy S. 610 - Credit Union Board Modernization Act S.2860 - Secure and Fair Enforcement Regulation Banking Act S. 1323 - Secure and Fair Enforcement Banking Act S. 2760 - Capping Credit Card Interest Rates Act S. 3538, Close the Shadow Banking Loophole Act Issues related to the National Defense Authorization Act Issues related to the Consumer Financial Protection Board Issues related to consumer financial protection Issues related to Community Development Financial Institutions Issues related to the Community Development Revolving Loan Fund Issues related to Credit Union Loan Maturities Issues related to Digital Assets Credit Union Tax Status Issues related to Financial Services Regulatory Relief Issues related to National Credit Union Administration Examination Procedures Proposed new tax reporting requirements for financial institutions Postal Banking Issues related to FinCEN and appropriations thereto Issues related to privately insured credit unions Issues related to the Federal Reserves new liquidity facility Issues related to the safety and soundness of credit unions Issues related to the Military Lending Act Issues related to regulation of Credit Unions as employers Issues related to Housing Finance Reform Issues related to management and operation of Credit Unions Issues related to Large Participants for General-Use Digital Consumer Payment Applications Foreign Account Tax Compliance Act Issues related to minority depository institutions Issues related to diversity, equity, and inclusion initiatives Issues related Credit Card Late Fee Rule H.R. 4868, the Member Business Loan Expansion Act S. 3992, Protecting Access to Credit for Small Businesses Act H.R. 6933, the Expanding Access to Lending Options Act H.R. 3161, the CDFI Fund Transparency Act H.R. 7338, the Rural Credit Access Act of 2024 Issues related to third party vendor authority Issues related to changes to NCUA call report re overdraft/non-sufficient funds fee disclosures Issues related to NCUA request for comment on climate-related financial risk Issues related to Overseas Military Banking Program Issues related to Greenhouse Gas Reduction Fund Issues related to CFPB Junk Fees Regulations Issues related to Federal Home Loan Banks Issues related to Overdraft and Non-sufficient Funds Fees Issues related to Fair Lending Issues related to premium assessments by the National Credit Union Share Insurance Fund Issues related to credit union conversions Issues related to capital reform for credit unions Issues related to Financial inclusion Issues related to Unfair, Deceptive, or Abusive acts or practices Issues related to Credit Union Fintech Investment Authority H.J.Res. 122 - Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to "Credit Card Penalty Fees (Regulation Z) H.R. 7440 Financial Services Innovation Act Issues related to AI in financial services H.R. 7036 Strengthening Cybersecurity for the Financial Sector Act H.R. 7000; S. 3592 Business of Insurance Regulatory Reform Act Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements EPA Greenhouse Gas Reduction Fund Issues related to flood insurance Issues related to Credit Union Service Organizations (CUSO)

The Veteran Member Business Loan Act (S. 539/H.R. 4867) would exempt loans made to veteran-owned businesses from the credit union member business lending cap. The Credit Card Competition Act (S. 1838/H.R. 3881) would weaken the security of the credit card payments network through regulating the credit card interchange market. The CDFI Fund Transparency Act (H.R. 3161) would increase awareness of the CDFI application process. The CFPB-IG Reform Act (H.R. 1411/S. 915) would require a Senate-confirmed Inspector General to help oversee the CFPB. H.R. 1382, the TABS Act, would bring the CFPB under the traditional congressional appropriations process. H.R. 1410 (the Consumer Financial Protection Commission Act) would establish a five-member Board of Directors for the CFPB. HR 7531, the Secure Payments Act, would prevent finalization of the Federal Reserve's proposal to cap debit card interchange fees until a study is conducted on the impact to financial services, consumers, and financial institutions.

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

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), SENATE

The Veteran Member Business Loan Act (S. 539/H.R. 4867) would exempt loans made to veteran-owned businesses from the credit union member business lending cap. The Credit Card Competition Act (S. 1838/H.R. 3881) would weaken the security of the credit card payments network through regulating the credit card interchange market. The CDFI Fund Transparency Act (H.R. 3161) would increase awareness of the CDFI application process. The CFPB-IG Reform Act (H.R. 1411/S. 915) would require a Senate-confirmed Inspector General to help oversee the CFPB. H.R. 1382, the TABS Act, would bring the CFPB under the traditional congressional appropriations process. H.R. 1410 (the Consumer Financial Protection Commission Act) would establish a five-member Board of Directors for the CFPB. HR 7531, the Secure Payments Act, would prevent finalization of the Federal Reserve's proposal to cap debit card interchange fees until a study is conducted on the impact to financial services, consumers, and financial institutions.

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

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), SENATE

H.R. 758 Promoting Access to Capital in Underbanked Communities Act of 2023 H.R. 1122 Central Bank Digital Currency Anti-Surveillance State Act H.R. 1165 Financial Data Privacy Act of 2023 H.R. 1806 Small LENDER Act H.R. 1810 Bank Loan Privacy Act H.R. 2656 Trigger Leads Abatement Act H.R. 2891 SAFER Banking Act of 2023 H.R. 3161, CDFI Fund Transparency Act H.R. 3881 Credit Card Competition Act of 2023 H.R. 4035, Protecting Small Business Information Act of 2023 H.R. 4198 To amend section 604(c) of the Fair Credit Reporting Act to address the treatment of pre-screening report requests, and for other purposes. H.R. 4366 Further Consolidated Appropriations Act, 2024 - Credit Card Competition Act Amendment H.R. 4766 Clarity for Payment Stablecoins Act of 2023 H.R. 5403, CBDC Anti-Surveillance State Act H.R. 6789 - Rectifying Undefined Descriptions of Abusive Act and Practices Act H.R. 7297 Homebuyers Privacy Protection Act H.R. 7420 Ensuring Diversity in Community Banking Act H.R. 7483, Expanding Opportunity for MDIs Act H.R. 7531 Secure Payments Act H.J.Res.121 Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to "Credit Card Penalty Fees (Regulation Z)" H.J. Res 122 Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to "Credit Card Penalty Fees (Regulation Z)". S. 1323 SAFE Banking Act of 2023 S. 1838 Credit Card Competition Act of 2023; Durbin Amendment on Debit Card Routing; Extension to Credit Cards S. 2190 RECOUP Act S. 2281 Lummis-Gillibrand Responsible Financial Innovation Act S. 2760, The Capping Credit Card Interest Rates Act S. 2860 SAFER Banking Act S. 3502 Homeowners Privacy Protection Act (Trigger Leads) S. 3538 Close the Shadow Banking Loophole Act S. 3801 CBDC Anti-Surveillance State Act S.J. Res. 32 A Resolution of Disapproval under the Congressional Review Act Re: Dodd-Frank Section 1071 Anti-money laundering regulation - digital assets Artificial Intelligence Beneficial Ownership Cannabis Banking Central Bank Digital Currency Check Fraud Climate Risk Disclosure Requirements Climate Related Financial Regulation Community Bank Access to Capital Community Development Financial Institutions Certification Community Reinvestment Act Credit Card Routing Mandates Credit Reporting Credit Union Acquisitions of Community Banks Credit Union Business Lending Powers Credit Union Field of Membership Rules Crypto Assets, Decentralized Finance, and Central Bank Digital Currency Cryptocurrency Regulation De Novo Bank Formation Debit Card Interchange Fees and Routing Deposit insurance reform Digital Assets Regulation Dodd Frank Act 1071- Small Business Loan Data Collection EGRPRA Review FDIC Guidelines for Establishing Standards for Corporate Governance and Risk Management for Covered Institutions with Total Consolidated Assets of $10 Billion or More FHFA Capital Rules Flood Insurance Implementation of Dodd Frank Act Section 1071 Implementation issues with the Anti-Money Laundering Act of 2020 Industrial Loan Company Charter Policy Instant Payments Interest rate caps Issues associated with the Federal Reserves discount window NSF and Overdraft Fees Opposing the SBAs proposal to repeal the moratorium on the number of Small Business Lending Companies (SBLC) that are permitted to make 7(a) loans. Request for hearing on unfair Credit Union Competition Request that the CFPBs FCRA Rulemaking Process be Subject to an Advanced Notice of Proposed Rulemaking (ANPR) before it Publishes a Notice of Proposed Rulemaking (NPRM) SBA Direct 7(a) Direct Lending Special Purpose Credit Programs (SPCPs) Stablecoin, Crypto Currency Regulatory Policy

Work to keep insurance regulated by the states and not by the Consumer Financial Protection Bureau or set by international bodies. Oppose legislation to repeal the McCarran-Ferguson antitrust exemption for the business of insurance. Advocate for privacy measures in line with GLBA and HIPAA as applied to financial services. Support H.R. 1165, the Data Privacy Act introduced by HFSC Chairman McHenry. Support legislation of e-signatures, e-disclosures, and e-notarizations, including E-Sign Modernization Act. Support H.R.1059, SECURE Notarization Act. Support S. 869, the CDFI Bond Guarantee Program Improve Act. Support H.R. 3161, the CDFI Fund Transparency Act, which would require the Fund's Director to testify annually before the HFS and SB Committees. Support increased CDFI and MDI funding in President's FY 2024 Budget Proposal and House Appropriations FSSC Bill. Support H.R. 2891/S. 1323/S. 2860, the Secure and Fair Enforcement Banking SAFE Act and Secure and Fair Enforcement Regulation Banking (SAFER) Act. This bill generally prohibits a federal regulator from penalizing a financial institution for providing services to a legitimate cannabis-related business. Oppose H.R. 3881/S. 1838, the Credit Card Competition Act, a bill that would reduce interchange fees on credit cards. Support H.R. 1807, Improving Disclosure for Investors Act of 2023, to provide electronic delivery of SEC regulatory documents. Included in H.R. 2799, Expanding Access to Capital Act. Support H.R. 500, Financial Exploitation Prevention Act. H.R. 7036, Strengthening Cyber Security for the Financial Sector Act. Working to exclude the "business of insurance" from NCUA's third party vendor bill, keeping insurance regulated by the states. Support H.R. 7440, Financial Services Innovation Act, which develops regulatory pathways for facilitating responsible innovation in fintech.

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.

The Veteran Member Business Loan Act (S. 539/H.R. 4867) would exempt loans made to veteran-owned businesses from the credit union member business lending cap. The Credit Card Competition Act (S. 1838/H.R. 3881) would weaken the security of the credit card payments network through regulating the credit card interchange market. The CDFI Fund Transparency Act (H.R. 3161) would increase awareness of the CDFI application process.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

The Veteran Member Business Loan Act (S. 539/H.R. 4867) would exempt loans made to veteran-owned businesses from the credit union member business lending cap. The Credit Card Competition Act (S. 1838/H.R. 3881) would weaken the security of the credit card payments network through regulating the credit card interchange market. The CDFI Fund Transparency Act (H.R. 3161) would increase awareness of the CDFI application process.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Work to keep insurance regulated by the states and not by the Consumer Financial Protection Bureau or set by international bodies. Oppose legislation to repeal the McCarran-Ferguson antitrust exemption for the business of insurance. Advocate for privacy measures in line with GLBA and HIPAA as applied to financial services. Support H.R. 1165, the Data Privacy Act introduced by HFSC Chairman McHenry. Support legislation of e-signatures, e-disclosures, and e-notarizations, including E-Sign Modernization Act. Support H.R.1059, SECURE Notarization Act. Support S. 869, the CDFI Bond Guarantee Program Improve Act. Support H.R. 3161, the CDFI Fund Transparency Act, which would require the Fund's Director to testify annually before the HFS and SB Committees. Support increased CDFI and MDI funding in President's FY 2024 Budget Proposal and House Appropriations FSSC Bill. Support H.R. 2891/S. 1323/S. 2860, the Secure and Fair Enforcement Banking SAFE Act and Secure and Fair Enforcement Regulation Banking (SAFER) Act. This bill generally prohibits a federal regulator from penalizing a financial institution for providing services to a legitimate cannabis-related business. Oppose H.R. 3881/S. 1838, the Credit Card Competition Act, a bill that would reduce interchange fees on credit cards. Support H.R. 1807, Improving Disclosure for Investors Act of 2023, to provide electronic delivery of SEC regulatory documents. Support H.R. 500, Financial Exploitation Prevention Act.

Client expense: $110,000 · Firm income: Not reported

Credit Union Board Modernization Act (S. 610) would modernize board meetings for federal credit unions. The Veteran Member Business Loan Act (S. 539) would exempt loans made to veteran-owned businesses from the credit union member business lending cap. Agent Members of the Central Liquidity Facility (S. 544) would provide immediate access to liquidity for smaller credit unions. The SAFE Banking Act (S. 1323/H.R. 2891) would provide protections for financial institutions accepting cannabis business. The Credit Card Competition Act (S. 1838/H.R. 3881) would weaken the security of the credit card payments network. The CDFI Fund Transparency Act (H.R. 3161) would increase awareness of the CDFI application process. The Consumer Financial Protection Commission Act (H.R. 1410) would establish a bipartisan five member commission for the CFPB. The Taking Account of Bureaucrats Spending Act (H.R. 1382) would subject the CFPB to the traditional appropriations process.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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.

Work to keep insurance regulated by the states and not by the Consumer Financial Protection Bureau or set by international bodies. Oppose legislation to repeal the McCarran-Ferguson antitrust exemption for the business of insurance. Advocate for privacy measures in line with GLBA and HIPAA as applied to financial services. Support H.R. 1165, the Data Privacy Act introduced by HFSC Chairman McHenry. Support legislation of e-signatures, e-disclosures, and e-notarizations, including E-Sign Modernization Act. Support H.R.1059, SECURE Notarization Act. Support S. 869, the CDFI Bond Guarantee Program Improve Act. Support H.R. 3161, the CDFI Fund Transparency Act, which would require the Fund's Director to testify annually before the HFS and SB Committees. Support increased CDFI and MDI funding in President's FY 2024 Budget Proposal and House Appropriations FSSC Bill. Support H.R. 2891/S. 1323/S. 2860, the Secure and Fair Enforcement Banking SAFE Act and Secure and Fair Enforcement Regulation Banking (SAFER) Act. This bill generally prohibits a federal regulator from penalizing a financial institution for providing services to a legitimate cannabis-related business. Oppose H.R. 3881/S. 1838, the Credit Card Competition Act, a bill that would reduce interchange fees on credit cards. Support H.R. 1807, Improving Disclosure for Investors Act of 2023, to provide electronic delivery of SEC regulatory documents. Support H.R. 500, Financial Exploitation Prevention Act.

Client expense: $110,000 · Firm income: Not reported

Credit Union Board Modernization Act (S. 610) would modernize board meetings for federal credit unions. The Veteran Member Business Loan Act (S. 539) would exempt loans made to veteran-owned businesses from the credit union member business lending cap. Agent Members of the Central Liquidity Facility (S. 544) would provide immediate access to liquidity for smaller credit unions. The SAFE Banking Act (S. 1323/H.R. 2891) would provide protections for financial institutions accepting cannabis business. The Credit Card Competition Act (S. 1838/H.R. 3881) would weaken the security of the credit card payments network. The CDFI Fund Transparency Act (H.R. 3161) would increase awareness of the CDFI application process. The Consumer Financial Protection Commission Act (H.R. 1410) would establish a bipartisan five member commission for the CFPB. The Taking Account of Bureaucrats Spending Act (H.R. 1382) would subject the CFPB to the traditional appropriations process.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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.

Work to keep insurance regulated by the states and not by the Consumer Financial Protection Bureau or set by international bodies. Oppose legislation to repeal the McCarran-Ferguson antitrust exemption for the business of insurance. Advocate for privacy measures in line with GLBA and HIPAA as applied to financial services. Support H.R. 1165, the Data Privacy Act introduced by HFSC Chairman McHenry. Support legislation of e-signatures, e-disclosures, and e-notarizations, including E-Sign Modernization Act. Support H.R.1059, SECURE Notarization Act. Support S. 869, the CDFI Bond Guarantee Program Improve Act. Support H.R. 3161, the CDFI Fund Transparency Act, which would require the Fund's Director to testify annually before the HFS and SB Committees. Support increased CDFI and MDI funding in President's FY 2024 Budget Proposal and House Appropriations FSSC Bill. Support H.R. 2891/S. 1323, the Secure and Fair Enforcement Banking SAFE Act - This bill generally prohibits a federal regulator from penalizing a financial institution for providing services to a legitimate cannabis-related business. Oppose H.R. 3881/S. 1838, the Credit Card Competition Act, a bill that would reduce interchange fees on credit cards. Support H.R. 1807, Improving Disclosure for Investors Act of 2023, to provide electronic delivery of SEC regulatory documents. Support H.R. 500, Financial Exploitation Prevention Act.

Client expense: $120,000 · Firm income: Not reported