Member Business Loan Expansion Act

Bank On Certification Program Central Bank Digital Currency Cryptocurrency Deposit Insurance Digital Assets Bank Capital Requirements/Basel Capital Proposal Postal Banking S.1323 & H.R.2891, Secure and Fair Enforcement (SAFE) Banking Act of 2023 H.R.4177 & S.2007, Improving Corporate Governance Through Diversity Act of 2023 H.R.2547, Comprehensive Debt Collection Improvement Act S.3937 & H.R.758, Promoting Access to Capital in Underbanked Communities Act of 2023 H.R. 1533 & S. 2252, Promoting New and Diverse Depository Institutions Act Emergency Capital Investment Issues for CDFI and MDI Institutions H.R.7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on banking UDAAP Supervisory Policies and Adjudication Procedures Community Reinvestment Act Final Rule Deposit Insurance Issues S.1838 & H.R.3881 Credit Card Competition Act of 2023 S.4760, Digital Commodities Consumer Protection Act of 2022 Merchant Category Codes S.1790, Failed Bank Executives Clawback Act S.293 & H.R.2743, Fair Access to Banking Act H.R.2799, Expanding Access to Capital Act of 2023 H.R.2603, To require the Securities and Exchange Commission to revise certain thresholds related to smaller reporting companies, accelerated filers, and large accelerated filers, and for other purposes H.R.2798, Consumer Financial Protection Bureau Transparency and Accountability Reform Act H.R.1382, TABS Act of 2023 H.R.1411, Consumer Financial Protection Bureau-Inspector General Reform Act H.R.2489, the Consumer Financial Protection Bureau Dual Mandate and Economic Analysis Act H.R.1313, the Transparency in Consumer Financial Protection Bureau Cost-Benefit Analysis Act H.R.1719, Making the Consumer Financial Protection Bureau Accountable to Small Business Act S.1362, the Transparency in Consumer Financial Protection Bureau Cost-Benefit Analysis Act H.R.490, Federal Infrastructure Bank Act of 2023 H.R.4868, Member Business Loan Expansion Act H.R.4035, Protecting Small Business Information Act of 2023 S.2760, Capping Credit Card Interest Rates Act H.R.5485, Financial Privacy Act of 2023 H.R.5524, Foreign Affiliate Sharing Pilot Program H.R.5403, Central Bank Digital Currency Anti-Surveillance Act H.R.5741, Uniform Treatment of Custodial Assets Act S.2860, Secure and Fair Enforcement Regulation (SAFER) Banking Act H.R.4763, Financial Innovation and Technology for the 21st Century Act H.R.4766, Clarity for Payment Stablecoins Act of 2023 S.2190, Recovering Executive Compensation Obtained Through Unaccountable Practices (RECOUP) Act of 2023 S.2251, Federal Information Security Modernization Act H.R.3398, Safe Access to Cash Act of 2023 S.3549, the Predatory Lending Elimination Act H.R.6789, Rectifying UDAAP Act H.R.1810, Bank Loan Privacy Act H.R.1806/S.1159, Small Lender Act H.R.4346, Small Bank Holding Company Relief Act of 2023 H.R.4198, Protecting Consumers from Abusive Mortgage Leads Act Regulation II: Debit Card Interchange Fees and Routing Implementation of Dodd-Frank Act Section 1033: Proposed Rule on Personal Financial Data Rights Merger and Acquisition Policy S.3554, Financial Artificial Intelligence Risk Reduction Act Artificial Intelligence Risk Management, Regulation, and Innovation CDFI Certification Update H.R.7531 & S.4570, Secure Payments Act of 2024 H.R.7437, Fostering Use of Technology to Uphold Regulatory Effectiveness in Supervision Act (FUTURES Act) H.R.4206, Bank Safety Act H.J.Res.122 & S.J.Res.70, Providing for Congressional disapproval under Chapter 8 of Title 5, U.S. Code, of the rule submitted by the Consumer Financial Protection Bureau related to Credit Card Penalty Fees (Reg Z) Notice of Proposed Rulemaking for Debit Card Interchange Fees and Routing (Reg II) Department of Labor Fiduciary Rule H.J.Res.140, 141, 142, and 143-Congressional Review Act Resolutions of Disapproval of the Department of Labor Fiduciary Rule S.J.Res.79, Congressional Review Act Resolution of Disapproval of the Department of Labor Fiduciary Rule Federal Reserve Discount Window and Emergency Lending Authority Guidelines for Establishing Standards for Corporate Governance and Risk Management for Covered Institutions with Total Consolidated Assets of $10 Billion or More CFPB Larger Participant of a Market for General-Use Digital Consumer Payment Applications H.R.8337, Bank Resilience and Regulatory Improvement Act H.R.8338, Clarity in Lending Act H.R.8288, Bringing the Discount Window into the 21st Century Act H.R.8287, Stress Testing Accountability and Transparency Act H.R.8264, Bank Supervision Appeals Improvement Act of 2024 H.R.8356, Small Dollar Loan Certainty Act H.R.7403, Bank Failure Prevention Act of 2024H.R.7437, Fostering the Use of Technology to Uphold Regulatory Effectiveness in Supervision (FUTURES) Act H.R.4206, Bank Safety Act Tokenization of Assets Fraud Issues Peer-To-Peer Payment Fraud FDIC Proposed Guidelines for Corporate Governance and Risk Management for Banks Over $10 Billion in Assets Pilot program allowing Freddie Mac to purchase single family closed-end second mortgages National Bank Act & Defending Dual Banking System S. 4943/H.R. 9303 Protecting Consumers From Payment Scams Act Financial Data Transparency Act Rulemaking FDIC Brokered Deposit Proposal H.R.7420 Ensuring Diversity in Community Banking Act

Client expense: $1,760,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

H.J.Res.50, 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 "Small Business Lending Under the Equal Credit Opportunity Act (Regulation B) H.J.Res.66, Disapproving of the rule submitted by the Consumer Financial Protection Bureau relating to Small Business Lending Under the Equal Credit Opportunity Act (Regulation B) S.J.Res.32, 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 Small Business Lending Under the Equal Credit Opportunity Act (Regulation B) SBA 7(a) Lending Program Credit union member business lending H.R.4868, Member Business Loan Expansion Act S.2482, Community Advantage Loan Program Act of 2023 H.R. 7198, Prove It Act

Client expense: $1,760,000 · Firm income: Not reported

Protect the credit union tax exemption Support legislation and regulation that advance credit unions and their over 140 million members Support regulatory relief for credit unions Support credit union field of membership expansion and modernization Support regulator- and bank-approved credit union-bank mergers Support financial inclusion and increased access to financial services Support assistance for minority depository institution credit unions Oppose Community Reinvestment Act requirements for credit unions Support Federal Credit Union Act modernization Support expanded credit union investment authority Support expanded credit union examination cycle Support increased examination transparency Support Central Liquidity Facility enhancements Oppose NCUA examination of credit union vendors Support parity for credit union provision of digital asset services Prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products Support parity for credit unions related to stablecoin regulation Support modification of credit union loan maturity limits Oppose National Credit Union Share Insurance Fund structural changes Oppose National Credit Union Share Insurance Fund premium assessment Support Community Development Financial Institutions Fund transparency Issues related to housing finance reform Issues related to flood insurance Issues related to privately insured credit unions Issues related to credit union capital requirements Issues related to credit union conversions Issues related to credit unions as employers Issues related to the Foreign Account Tax Compliance Act Issues related to fair lending Issues related to the Telephone Consumer Protection Act Support mandatory arbitration agreements Oppose national interest rate cap Support reduced government-sponsored enterprises costs for credit union mortgages Support secondary mortgage market access for credit unions Support credit union access to Federal Home Loan Banks system 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 unfair, deceptive, or abusive acts and practices 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 mislabeling financial services fees as junk fees Oppose arbitrary limits on credit union fee income Support federal data privacy and security standard that exempts Gramm-Leach-Bliley Act covered institutions, preempts state laws, and does not authorize private right of action Oppose Regulation II debit interchange fee cap Oppose Federal Reserve proposed rule on modifying Regulation II debit interchange cap Support holistic evaluation of regulatory burden on credit unions Oppose expansion of Electronic Fund Transfer Act/Regulation E financial institution liability Support fair distribution of Electronic Fund Transfer Act/Regulation E error resolution responsibilities Oppose Electronic Fund Transfer Act/Regulation E liability for financial institutions for consumer-authorized transactions Oppose nominal leases for banks on military installations Oppose development of a central bank digital currency Oppose proposed new tax reporting requirements for financial institutions Support credit union access to Federal Reserve liquidity options 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 National Defense Authorization Act 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 Secure and Fair Enforcement Banking Act (H.R. 2891; S. 1323) Support Secure And Fair Enforcement Regulation Banking Act (S. 2860) Oppose Capping Credit Card Interest Rates Act (S. 2760) Support Close the Shadow Banking Loophole Act (S. 3538) Support Business of Insurance Regulatory Reform Act (H.R. 7000; S. 3592) Oppose Strengthening Cybersecurity for the Financial Sector Act (H.R. 7036) Support resolution of disapproval for CFPB credit card penalty fees final rule (S.J.Res. 70; H.J.Res. 122) Support CBDC Anti-Surveillance State Act (H.R. 5403; S. 3801) Support CDFI Fund Transparency Act (S. 3161; S. 2674) Support Consumer Financial Protection Commission Act (H.R. 1410) Support CFPB Transparency and Accountability Reform Act (H.R. 2798) Support Fair Audits and Inspections for Regulators Exams Act (H.R. 8071) Support Credit Union Board Modernization Act (H.R. 582, S. 610) Support Member Business Loan Expansion Act (H.R. 4868) Support Veterans Member Business Loan Act (H.R. 4867; S. 539) Support Expanding Access to Lending Options Act (H.R. 6933) Oppose House National Defense Authorization Act Amendment #645 on the Overseas Military Banking Program Support Rural Credit Access Act (H.R. 7338) 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 inclusion of American Privacy Rights Act as amendment to other legislation Oppose Protecting Consumers from Payment Scams Act (H.R. 9303; S. 4943) Support Affordable Future Loan Program Act (S. 4926) Oppose CFPB credit card penalty fees final rule Oppose CFPB Section 1071 final rule Oppose CFPB Section 1033 proposed rule Oppose NCUA Call Report collection of overdraft and NSF fee revenue data Oppose NCUA disclosure of credit union overdraft and NSF fee revenue data Support NCUA action to permit credit union reimbursement of childcare expenses for federal credit union board meetings Oppose collection of vendor information in NCUA Credit Union Profile Oppose changes to NCUA collection forms outside rulemaking process Oppose NCUA proposed rule on succession planning Oppose CFPB mischaracterization of overdraft programs Oppose CFPB proposed rule on modifications to mortgage loss mitigation regulations Support gradual expansion of Fedwire and National Settlement Service operating hours with optional participation Support NCUA recognition of digital banking in service facility definition Support clarification of NCUA member expulsion regulations Support NCUA proposed rule on increasing overdraft flexibility Support NCUA recognition of government sponsored enterprises as government agencies for loan maturity limit purposes Support NCUA adoption of floating interest rate cap Support modification of NCUA commercial loan definition Support increased flexibility in NCUA occupancy requirements Support NCUA modification of low-income designation process Support expanding NCUA qualified charity definition Support expansion of Federal Home Loan Bank Act community financial institution definition Support Federal Home Loan Bank engagement with credit unions Oppose adoption of volume-based incentives for Federal Home Loan Banks Oppose policy changes to limit access to Federal Home Loan Bank liquidity Support harmonization of federal cyber incident notification standards Oppose CFPB action to shift burden of negotiating mortgage closing fees to financial institutions Support credit union access to universal service fund letters of credit program Support additional time to implement anti-money laundering/countering financing of terrorism program changes and publication of guidance Support consumer protection regulations for buy-now-pay-later loan providers Support regulatory framework for artificial intelligence that allows responsible innovation and recognizes compliance with existing regulations Oppose prohibition on use of medical debt information in credit decisions

Lapses by the retail industry/merchants in securing consumer information continue to be extremely problematic and costly to consumers and financial institutions. MCUL is advocating that Congress hold retailers to the same or similar data security standards as the financial service industry has to abide by and require retailers notify credit unions sooner once a breach occurs. We support the introduction of legislation that ensures all businesses, institutions and organizations that collect, use or share personal data are subject to national standards, to include language that preempts state requirements, among other things. MCUL supports modernizing the Federal Credit Union Act (FCUA). The financial service industry is rapidly changing. Advancements in technology, including high speed internet connectivity, have significantly changed our society and how financial institutions do business. Updating the FCUA has become necessary to ensure federally chartered credit unions have the powers and flexibility to be competitive and members can benefit from new technology. We are currently supporting S. 539/H.R.4867, the Veterans Member Business Loan Act that would exempt credit union business loans to veterans from the member business lending cap and we are supporting H.R. 582/S.610, the Credit Union Board Modernization Act which would afford federal credit unions flexibility with regard to how often their boards meet. In addition, we are calling on Congress to pass H.R. 4868, the Member Business Loan Expansion Act, allowing the NCUA to extend the maturity limit on non-mortgage loans. MCUL is monitoring developments for GSE/housing finance reform and will advocate to make sure any reforms reflect the significant role credit unions play in the secondary mortgage market and we will defend against anything that is potentially harmful to credit unions and our members. MCUL is calling on Congress to pass bank secrecy act/anti-money laundering reforms and provide financial institutions relief from unnecessary, duplicate and burdensome rules and increase the SAR and CTR thresholds. MCUL is educating members of our congressional delegation on the growing interest among credit union members and credit unions in cryptocurrency. We believe Congress should explore ways to regulate the delivery of financial services using digital currencies to ensure consumers are protected in the same way if they received financial services from a financial institution. We urge Congress to look for ways to enable credit unions and other financial institutions to provide digital assets, so that these services can be properly overseen by federal regulators. Finally, credit unions seek parity with other financial institutions in this area as credit unions must be able to offer digital/crypto products and services directly to their members in the same way that other institutions can to their customers. MCUL is urging Congress to amend H.R. 4766, the Clarity for Payment Stablecoins Act of 2023, to remove current competitive barriers for credit unions in stablecoin legislation. MCUL remains opposed to a proposal by the U.S. Treasury Department and that has been discussed in Congress that would require financial institutions to report on an annual basis, the gross inflows and outflows, for member accounts (businesses and individuals). We have been educating our congressional delegation on the issue and urging them to reject including the proposal in future legislation. MCUL opposes H.R. 9303/S.4943, the Protecting Consumers from Payment Scams Act of 2024 provided the bill fails to tackle the root causes of criminal activity that have left consumers vulnerable to fraud/scams, does not provide resources to improve consumer education about fraud/scams and would impose severe costs on credit unions and dramatically alter their ability to absorb future loses. Lastly, credit unions are not-for-profit member-owned financial institutions, owned by members they service. Credit unions consumer-focused model is self-regulating and a principal reason why credit unions are not covered by the Community Reinvestment Act (CRA). MCUL will educate members of the delegation of the work credit unions are doing to serve low/moderate-income, diverse communities and the negative impacts of including credit unions in the CRA. We will oppose efforts that would result in credit unions of any size being included in the CRA.

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.J. Res. 50, 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 "Small Business Lending Under the Equal Credit Opportunity Act (Regulation B) H.J. Res. 66, Disapproving of the rule submitted by the Consumer Financial Protection Bureau relating to Small Business Lending Under the Equal Credit Opportunity Act (Regulation B) S.J. Res. 32, 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 Small Business Lending Under the Equal Credit Opportunity Act (Regulation B) SBA 7(a) Lending Program Credit union member business lending H.R. 4868, Member Business Loan Expansion Act S. 2482, Community Advantage Loan Program Act of 2023

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

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

Lapses by the retail industry/merchants in securing consumer information continue to be extremely problematic and costly to consumers and financial institutions. MCUL is advocating that Congress hold retailers to the same or similar data security standards as the financial service industry has to abide by and require retailers notify credit unions sooner once a breach occurs. We support the introduction of legislation that ensures all businesses, institutions and organizations that collect, use or share personal data are subject to national standards, to include language that preempts state requirements, among other things. MCUL supports modernizing the Federal Credit Union Act (FCUA). The financial service industry is rapidly changing. Advancements in technology, including high speed internet connectivity, have significantly changed our society and how financial institutions do business. Updating the FCUA has become necessary to ensure federally chartered credit unions have the powers and flexibility to be competitive and members can benefit from new technology. We are currently supporting S. 539/H.R.4867, the Veterans Member Business Loan Act that would exempt credit union business loans to veterans from the member business lending cap and we are supporting H.R. 582/S.610, the Credit Union Board Modernization Act which would afford federal credit unions flexibility with regard to how often their boards meet. In addition, we are calling on Congress to pass H.R. 4868, the Member Business Loan Expansion Act, allowing the NCUA to extend the maturity limit on non-mortgage loans. MCUL is monitoring developments for GSE/housing finance reform and will advocate to make sure any reforms reflect the significant role credit unions play in the secondary mortgage market and we will defend against anything that is potentially harmful to credit unions and our members. MCUL is calling on Congress to pass bank secrecy act/anti-money laundering reforms and provide financial institutions relief from unnecessary, duplicate and burdensome rules and increase the SAR and CTR thresholds. MCUL is educating members of our congressional delegation on the growing interest among credit union members and credit unions in cryptocurrency. We believe Congress should explore ways to regulate the delivery of financial services using digital currencies to ensure consumers are protected in the same way if they received financial services from a financial institution. We urge Congress to look for ways to enable credit unions and other financial institutions to provide digital assets, so that these services can be properly overseen by federal regulators. Finally, credit unions seek parity with other financial institutions in this area as credit unions must be able to offer digital/crypto products and services directly to their members in the same way that other institutions can to their customers. MCUL is urging Congress to amend H.R. 4766, the Clarity for Payment Stablecoins Act of 2023, to remove current competitive barriers for credit unions in stablecoin legislation. MCUL remains opposed to a proposal by the U.S. Treasury Department and that has been discussed in Congress that would require financial institutions to report on an annual basis, the gross inflows and outflows, for member accounts (businesses and individuals). We have been educating our congressional delegation on the issue and urging them to reject including the proposal in future legislation. Lastly, credit unions are not-for-profit member-owned financial institutions, owned by members they service. Credit unions consumer-focused model is self-regulating and a principal reason why credit unions are not covered by the Community Reinvestment Act (CRA). MCUL will educate members of the delegation of the work credit unions are doing to serve low/moderate-income, diverse communities and the negative impacts of including credit unions in the CRA. We will oppose efforts that would result in credit unions of any size being included in the CRA.

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)

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

H.J. Res. 50, 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 "Small Business Lending Under the Equal Credit Opportunity Act (Regulation B) H.J. Res. 66, Disapproving of the rule submitted by the Consumer Financial Protection Bureau relating to Small Business Lending Under the Equal Credit Opportunity Act (Regulation B) S.J. Res. 32, 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 Small Business Lending Under the Equal Credit Opportunity Act (Regulation B) SBA 7(a) Lending Program Credit union member business lending H.R. 4868, Member Business Loan Expansion Act S. 2482, Community Advantage Loan Program Act of 2023

Client expense: $1,750,000 · Firm income: Not reported

Lapses by the retail industry/merchants in securing consumer information continue to be extremely problematic and costly to consumers and financial institutions. MCUL is advocating that Congress hold retailers to the same or similar data security standards as the financial service industry has to abide by and require retailers notify credit unions sooner once a breach occurs. We support the introduction of legislation that ensures all businesses, institutions and organizations that collect, use or share personal data are subject to national standards, to include language that preempts state requirements, among other things. MCUL supports modernizing the Federal Credit Union Act (FCUA). The financial service industry is rapidly changing. Advancements in technology, including high speed internet connectivity, have significantly changed our society and how financial institutions do business. Updating the FCUA has become necessary to ensure federally chartered credit unions have the powers and flexibility to be competitive and members can benefit from new technology. We are currently supporting S. 539/H.R.4867, the Veterans Member Business Loan Act that would exempt credit union business loans to veterans from the member business lending cap and we are supporting H.R. 582/S.610, the Credit Union Board Modernization Act which would afford federal credit unions flexibility with regard to how often their boards meet. In addition, we are calling on Congress to pass H.R. 4868, the Member Business Loan Expansion Act, allowing the NCUA to extend the maturity limit on non-mortgage loans. MCUL is monitoring developments for GSE/housing finance reform and will advocate to make sure any reforms reflect the significant role credit unions play in the secondary mortgage market and we will defend against anything that is potentially harmful to credit unions and our members. MCUL is calling on Congress to pass bank secrecy act/anti-money laundering reforms and provide financial institutions relief from unnecessary, duplicate and burdensome rules and increase the SAR and CTR thresholds. MCUL is educating members of our congressional delegation on the growing interest among credit union members and credit unions in cryptocurrency. We believe Congress should explore ways to regulate the delivery of financial services using digital currencies to ensure consumers are protected in the same way if they received financial services from a financial institution. We urge Congress to look for ways to enable credit unions and other financial institutions to provide digital assets, so that these services can be properly overseen by federal regulators. Finally, credit unions seek parity with other financial institutions in this area as credit unions must be able to offer digital/crypto products and services directly to their members in the same way that other institutions can to their customers. MCUL is urging Congress to amend H.R. 4766, the Clarity for Payment Stablecoins Act of 2023, to remove current competitive barriers for credit unions in stablecoin legislation. MCUL remains opposed to a proposal by the U.S. Treasury Department and that has been discussed in Congress that would require financial institutions to report on an annual basis, the gross inflows and outflows, for member accounts (businesses and individuals). We have been educating our congressional delegation on the issue and urging them to reject including the proposal in future legislation. Lastly, credit unions are not-for-profit member-owned financial institutions, owned by members they service. Credit unions consumer-focused model is self-regulating and a principal reason why credit unions are not covered by the Community Reinvestment Act (CRA). MCUL will educate members of the delegation of the work credit unions are doing to serve low/moderate-income, diverse communities and the negative impacts of including credit unions in the CRA. We will oppose efforts that would result in credit unions of any size being included in the CRA.

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.

H.J.Res.50, 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 "Small Business Lending Under the Equal Credit Opportunity Act (Regulation B) H.J.Res.66. Disapproving of the rule submitted by the Consumer Financial Protection Bureau relating to Small Business Lending Under the Equal Credit Opportunity Act (Regulation B). S.J.Res.32. 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 Small Business Lending Under the Equal Credit Opportunity Act (Regulation B) SBA 7(a) Lending Program Credit union member business lending H.R. 4868, Member Business Loan Expansion Act S.2482, Community Advantage Loan Program Act of 2023

Client expense: $1,910,000 · Firm income: Not reported

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

Lapses by the retail industry/merchants in securing consumer information continue to be extremely problematic and costly to consumers and financial institutions. MCUL is advocating that Congress hold retailers to the same or similar data security standards as the financial service industry has to abide by and require retailers notify credit unions sooner once a breach occurs. We support the introduction of legislation that ensures all businesses, institutions and organizations that collect, use or share personal data are subject to national standards, to include language that preempts state requirements, among other things. MCUL supports modernizing the Federal Credit Union Act (FCUA). The financial service industry is rapidly changing. Advancements in technology, including high speed internet connectivity, have significantly changed our society and how financial institutions do business. Updating the FCUA has become necessary to ensure federally chartered credit unions have the powers and flexibility to be competitive and members can benefit from new technology. We are currently supporting S. 539/H.R.4867, the Veterans Member Business Loan Act that would exempt credit union business loans to veterans from the member business lending cap and we are supporting H.R. 582/S.610, the Credit Union Board Modernization Act which would afford federal credit unions flexibility with regard to how often their boards meet. In addition, we are calling on Congress to pass H.R. 4868, the Member Business Loan Expansion Act, allowing the NCUA to extend the maturity limit on non-mortgage loans. MCUL is monitoring developments for GSE/housing finance reform and will advocate to make sure any reforms reflect the significant role credit unions play in the secondary mortgage market and we will defend against anything that is potentially harmful to credit unions and our members. MCUL is calling on Congress to pass bank secrecy act/anti-money laundering reforms and provide financial institutions relief from unnecessary, duplicate and burdensome rules and increase the SAR and CTR thresholds. MCUL is educating members of our congressional delegation on the growing interest among credit union members and credit unions in cryptocurrency. We believe Congress should explore ways to regulate the delivery of financial services using digital currencies to ensure consumers are protected in the same way if they received financial services from a financial institution. We urge Congress to look for ways to enable credit unions and other financial institutions to provide digital assets, so that these services can be properly overseen by federal regulators. Finally, credit unions seek parity with other financial institutions in this area as credit unions must be able to offer digital/crypto products and services directly to their members in the same way that other institutions can to their customers. MCUL is urging Congress to amend H.R. 4766, the Clarity for Payment Stablecoins Act of 2023, to remove current competitive barriers for credit unions in stablecoin legislation. MCUL remains opposed to a proposal by the U.S. Treasury Department and that has been discussed in Congress that would require financial institutions to report on an annual basis, the gross inflows and outflows, for member accounts (businesses and individuals). We have been educating our congressional delegation on the issue and urging them to reject including the proposal in future legislation. Lastly, credit unions are not-for-profit member-owned financial institutions, owned by members they service. Credit unions consumer-focused model is self-regulating and a principal reason why credit unions are not covered by the Community Reinvestment Act (CRA). MCUL will educate members of the delegation of the work credit unions are doing to serve low/moderate-income, diverse communities and the negative impacts of including credit unions in the CRA. We will oppose efforts that would result in credit unions of any size being included in the CRA.

H.R. 6037, To prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program. H.J.Res.50, 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 "Small Business Lending Under the Equal Credit Opportunity Act (Regulation B) H.J.Res.66. Disapproving of the rule submitted by the Consumer Financial Protection Bureau relating to Small Business Lending Under the Equal Credit Opportunity Act (Regulation B). S.J.Res.32. 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 Small Business Lending Under the Equal Credit Opportunity Act (Regulation B) SBA 7(a) Lending Program Credit union member business lending H.R. 4868, Member Business Loan Expansion Act S.2482, Community Advantage Loan Program Act of 2023

Client expense: $2,160,000 · Firm income: Not reported

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

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

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

Lapses by the retail industry/merchants in securing consumer information continue to be extremely problematic and costly to consumers and financial institutions. MCUL is advocating that Congress hold retailers to the same or similar data security standards as the financial service industry has to abide by and require retailers notify credit unions sooner once a breach occurs. We support the introduction of legislation that ensures all businesses, institutions and organizations that collect, use or share personal data are subject to national standards, to include language that preempts state requirements, among other things. MCUL supports modernizing the Federal Credit Union Act (FCUA). The financial service industry is rapidly changing. Advancements in technology, including high speed internet connectivity, have significantly changed our society and how financial institutions do business. Updating the FCUA has become necessary to ensure federally chartered credit unions have the powers and flexibility to be competitive and members can benefit from new technology. We are currently supporting S. 539/H.R.4867, the Veterans Member Business Loan Act that would exempt credit union business loans to veterans from the member business lending cap and we are supporting H.R. 582/S.610, the Credit Union Board Modernization Act which would afford federal credit unions flexibility with regard to how often their boards meet. In addition, we are calling on Congress to pass H.R. 4868, the Member Business Loan Expansion Act, allowing the NCUA to extend the maturity limit on non-mortgage loans. MCUL is monitoring developments for GSE/housing finance reform and will advocate to make sure any reforms reflect the significant role credit unions play in the secondary mortgage market and we will defend against anything that is potentially harmful to credit unions and our members. MCUL is calling on Congress to pass bank secrecy act/anti-money laundering reforms and provide financial institutions relief from unnecessary, duplicate and burdensome rules and increase the SAR and CTR thresholds. MCUL is educating members of our congressional delegation on the growing interest among credit union members and credit unions in cryptocurrency. We believe Congress should explore ways to regulate the delivery of financial services using digital currencies to ensure consumers are protected in the same way if they received financial services from a financial institution. We urge Congress to look for ways to enable credit unions and other financial institutions to provide digital assets, so that these services can be properly overseen by federal regulators. Finally, credit unions seek parity with other financial institutions in this area as credit unions must be able to offer digital/crypto products and services directly to their members in the same way that other institutions can to their customers. MCUL is urging Congress to amend H.R. 4766, the Clarity for Payment Stablecoins Act of 2023, to remove current competitive barriers for credit unions in stablecoin legislation. MCUL remains opposed to a proposal by the U.S. Treasury Department and that has been discussed in Congress that would require financial institutions to report on an annual basis, the gross inflows and outflows, for member accounts (businesses and individuals). We have been educating our congressional delegation on the issue and urging them to reject including the proposal in future legislation. Lastly, credit unions are not-for-profit member-owned financial institutions, owned by members they service. Credit unions consumer-focused model is self-regulating and a principal reason why credit unions are not covered by the Community Reinvestment Act (CRA). MCUL will educate members of the delegation of the work credit unions are doing to serve low/moderate-income, diverse communities and the negative impacts of including credit unions in the CRA. We will oppose efforts that would result in credit unions of any size being included in the CRA.