Rural Credit Access Act of 2024

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 parity in deposit insurance coverage levels between credit unions and banks 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 proposed rule on NSF fees 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 NDAA 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) Support balanced regulatory framework in AI Act of 2024 (H.R. 10262) Oppose requirement for filing a single joint report in AI Act of 2024 (H.R. 10262) Support Central Liquidity Facility Enhancement Act (H.R. 10510) Support field of membership expansion in Expanding Financial Access for Underserved Communities Act (H.R. 10511) Oppose NDAA amendments on interchange and military banking Support passage of a clean NDAA Oppose CFPB credit card penalty fees final rule Oppose CFPB Section 1071 final rule Oppose CFPB Section 1033 final 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 consistency between NCUA and FinCEN requirements on Bank Secrecy Act compliance 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 Oppose addition of fourth same-day ACH window Support expanded flexibility for accessing the Fed discount window and intraday credit Oppose CFPB rulemaking activity before transition in administrations Oppose additional Call Report fields on loans to credit union officials and senior executive staff Oppose making changes to Call Report requirements without using notice-and-comment process Support enhanced clarity in proposed amendments to remittance rule Oppose CFPB efforts to manipulate consumer complaint data Oppose proposed incentive-based compensation rule Support recognition of unique credit union structure in Financial Data Transparency Act joint data standards

Client expense: $1,440,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Natl Credit Union Administration (NCUA), Office of Management & Budget (OMB), SENATE, Small Business Administration (SBA), Treasury, Dept of

H.R. 2423 The Farm Credit Administration Independent Authority Act H.R. 3139 ACRE Act H.R. 3787 Modernizing Agricultural and Manufacturing Bonds Act H.R. 4673 Financial Innovation and Technology for the 21st Century Act H.R. 4736 The Investing in Rural America Act H.R. 4940 The Fishing Industry Credit Enhancement Act H.R. 5631 The Producer and Agricultural Credit Enhancement Act of 2023 H.R. 5877 USDA Express Loan Act H.R. 6564 The Farm Credit Adjustment Act H.R. 7338 Rural Credit Access Act H.R. 8467 The Farm, Food, and National Security Act of 2024 - Farm Credit 1071 Exemption S. 1756 The Fishing Industry Credit Enhancement Act S. 2252 Promoting New and Diverse Depositories Act S. 2371 ACRE Act S. 2723 Modernizing Agricultural and Manufacturing Bonds Act S. 2890 Producer and Agricultural Credit Enhancement Act of 2023 S. 3497 The FARM Home Loans Act 2023 Farm Bill Reauthorization Adequate Farm Bill Spending Crop Insurance Cryptocurrency Regulation Digital Assets Regulation Durbin Amendment on Debit Card Routing; Extension to Credit Cards Farm Credit System Expansion Guaranteed Farm Loans Sec. 1071 of the Dodd Frank Act

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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

Client expense: $1,090,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Natl Credit Union Administration (NCUA), Office of Management & Budget (OMB), SENATE, Small Business Administration (SBA), Treasury, Dept of