Protecting Consumers From Payment Scams Act

Issues relating to banking institutions impacting reform. Additional matters related to Community Reinvestment Act (CRA); financial services regulatory reform, U.S. payments systems, anti-money laundering, beneficial ownership; nominations; and bank climate-related stress tests/scenario analysis. S.3600 Strengthening American Cybersecurity Act; S.1838, Credit Card Competition Act of 2023; S.2760, Capping Credit Card Interest Rates Act; H.R. 7531, Secure Payments Act of 2024; S.3538, Close the Shadow Banking Loophole Act; H.R. 9303, Protecting Consumers from Payment Scams Act; S.19, GENIUS Act of 2025, Guiding and Establishing National Innovation for U.S.; H.R. 2392, Stablecoin Transparency and Accountability for a Better Ledger Economy Act of 2025 (STABLE Act of 2025); S.J. Res. 18, A joint resolution disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Overdraft Lending: Very Large Financial Institutions"; and H.R. 3633, Digital Asset Market Clarity Act of 2025 (CLARITY).

Client expense: $400,000 · Firm income: Not reported

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

Issues relating to banking institutions impacting reform. Additional matters related to Community Reinvestment Act (CRA); financial services regulatory reform, U.S. payments systems, anti-money laundering, beneficial ownership; nominations; and bank climate-related stress tests/scenario analysis. S.3600 Strengthening American Cybersecurity Act; S.1838, Credit Card Competition Act of 2023; S.2760, Capping Credit Card Interest Rates Act; H.R. 7531, Secure Payments Act of 2024; S.3538, Close the Shadow Banking Loophole Act; H.R. 9303, Protecting Consumers from Payment Scams Act; S.19, GENIUS Act of 2025, Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025; H.R. 2392, STABLE Act of 2025, Stablecoin Transparency and Accountability for a Better Ledger Economy Act of 2025; S.J. Res. 18, A joint resolution disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Overdraft Lending: Very Large Financial Institutions"; and H.R. 3633, Digital Asset Market Clarity Act of 2025 (CLARITY).

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

Lobbied on changes to interchange, overdraft protection, junk fees, expansion of credit union member business lending, Regulation E expansion, succession planning requirements for credit unions, changes to credit union call report. Credit Card Competition Act of 2023 (S. 1838; H.R. 3881). Veteran Business Lending (Veterans Member Business Loan Act - H.R. 4867 & S.539). Protecting Consumers from Payments Scam Act (S. 4943, H.R. 9303)

Client expense: Not reported · Firm income: Not reported

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

Lobbied on changes to interchange, overdraft protection, junk fees, expansion of credit union member business lending, Regulation E expansion, succession planning requirements for credit unions, changes to credit union call report. Credit Card Competition Act of 2023 (S. 1838; H.R. 3881). Veteran Business Lending (Veterans Member Business Loan Act - H.R. 4867 & S.539). Protecting Consumers from Payments Scam Act (S. 4943, H.R. 9303)

Client expense: Not reported · Firm income: Not reported

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

Lobbied on changes to interchange, overdraft protection, junk fees, expansion of credit union member business lending, Regulation E expansion, succession planning requirements for credit unions, changes to credit union call report. Credit Card Competition Act of 2023 (S. 1838; H.R. 3881). Veteran Business Lending (Veterans Member Business Loan Act - H.R. 4867 & S.539). Protecting Consumers from Payments Scam Act (S. 4943, H.R. 9303)

Client expense: Not reported · Firm income: Not reported

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

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.

H.R. 758 Promoting Access to Capital in Underbanked Communities Act of 2023 H.R. 1806 Small LENDER Act H.R. 1810 Bank Loan Privacy Act H.R. 2656 Trigger Leads Abatement Act H.R. 2891 SAFER Banking Act of 2023 H.R. 3881 Credit Card Competition Act of 2023 H.R. 4766 Clarity for Payment Stablecoins Act of 2023 H.R. 5403 CBDC Anti-Surveillance State Act H.R. 7297 Homebuyers Privacy Protection Act H.R. 9303 Protecting Consumers from Payment Scams Act H.R. 10542 Employee Paycheck and Small Business Protection Act S. 1323 SAFE Banking Act of 2023 S. 1838 Credit Card Competition Act of 2023; Durbin Amendment on Debit Card Routing; Extension to Credit Cards S. 2860 SAFER Banking Act S. 3502 Homeowners Privacy Protection Act (Trigger Leads) S. 3538 Close the Shadow Banking Loophole Act S. 3801 CBDC Anti-Surveillance State Act S. 4155 Lummis -Gillibrand Payment Stablecoin Act S. 4570 Secure Payments Act S. 4638 National Defense Authorization Act for Fiscal Year 2025 S. 4943 Protecting Consumers from Payment Scams Act Senate Amendment 2358 to National Defense Authorization Act (Trigger Leads) Senate Amendment 3290 National Defense Authorization Act (Trigger leads) Anti-money laundering regulation - digital assets Artificial Intelligence Bank Merger Competitive Review Guidelines Bank-fintech partnerships Beneficial Ownership Cannabis Banking Central Bank Digital Currency Check Fraud Community Bank Access to Capital Community Development Financial Institutions Certification Credit Card Routing Mandates Credit Reporting Credit Union Acquisitions of Community Banks Credit Union Business Lending Powers Credit Union Field of Membership Rules Data Privacy De Novo Bank Formation Debit Card Interchange Fees and Routing Deposit Insurance Reform Digital Assets Regulation EGRPRA Review FHFA Capital Rules Flood Insurance Implementation of Dodd Frank Act Section 1071 Implementation issues with the Anti-Money Laundering Act of 2020 Industrial Loan Company Charter Policy Open Banking / Dodd-Frank Section 1033 Opposing the SBAs proposal to repeal the moratorium on the number of Small Business Lending Companies (SBLC) that are permitted to make 7(a) loans. Request for hearing on unfair Credit Union Competition Request that the CFPBs FCRA Rulemaking Process be Subject to an Advanced Notice of Proposed Rulemaking (ANPR) before it Publishes a Notice of Proposed Rulemaking (NPRM) SBA Direct 7(a) Direct Lending

Issues relating to banking institutions impacting reform. Matters related to Community Reinvestment Act (CRA). Current Expected Credit Loss (CECL); Paycheck Protection Program. Matters relating to financial services regulatory reform, U.S. payments systems, anti-money laundering, beneficial ownership; nominations; and bank climate-related stress tests/scenario analysis. S. 3600 Strengthening American Cybersecurity Act; S.1838, Credit Card Competition Act of 2023; S.2760, Capping Credit Card Interest Rates Act; H.R. 7531, Secure Payments Act of 2024; S.3538, Close the Shadow Banking Loophole Act; S.2190, Recovering Executive Compensation Obtained from Unaccountable Practices Act of 2023 (RECOUP Act of 2023); and H.R. 9303, Protecting Consumers from Payment Scams Act.

Client expense: $480,000 · Firm income: Not reported

Bank On Certification Program Central Bank Digital Currency Cryptocurrency Deposit Insurance Reform 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 Applying Community Reinvestment Act to credit unions 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: Final 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 CFPB Overdraft Rule H.R. 4212/S. 1938, Middle Class Mortgage Insurance Premium Act

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

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

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

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

Affordable Housing workforce economic development challenges, general education; digital currency and US payments systems, general education; flood insurance and home ownership, general education; small business access to capital and SBA, general education; CRA and community development, general education; Bank products, programs and fees for service, general education; safety and soundness of US banking system and role of regional banks, general education; Impacts of bank check fraud and consumer challenges, general education; Bank capital standards, long term debt, and Basel III, general education; bank merger and acquisition environment, general education; corporate social responsibility and sustainable business practices, general education; S.1838, Credit Card Competition Act, all provisions; H.R. 6363; H.R. 8152 American Privacy Rights Act, all provisions; H.R. 7531 Secure Payment Act, all provisions; S. 4943/H.R. 9303, Protecting Consumers form Payments Scams Act, all provisions; H.R. 9747, Continuing Appropriations and Extensions Act of 2025, urged passage and educated on impacts of shutdown

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Affordable Housing workforce economic development challenges, general education; digital currency and US payments systems, general education; flood insurance and home ownership, general education; small business access to capital and SBA, general education; CRA and community development, general education; Bank products, programs and fees for service, general education; safety and soundness of US banking system and role of regional banks, general education; Impacts of bank check fraud and consumer challenges, general education; Bank capital standards, long term debt, and Basel III, general education; bank merger and acquisition environment, general education; corporate social responsibility and sustainable business practices, general education; S.1838, Credit Card Competition Act, all provisions; H.R. 6363; H.R. 8152 American Privacy Rights Act, all provisions; H.R. 7531 Secure Payment Act, all provisions; S. 4943/H.R. 9303, Protecting Consumers form Payments Scams Act, all provisions; H.R. 9747, Continuing Appropriations and Extensions Act of 2025, urged passage and educated on impacts of shutdown

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Lobbied on changes to interchange, overdraft protection, junk fees, expansion of credit union member business lending, Regulation E expansion, succession planning requirements for credit unions, changes to credit union call report. Credit Card Competition Act of 2023 (S. 1838; H.R. 3881). Veteran Business Lending (Veterans Member Business Loan Act - H.R. 4867 & S.539). Protecting Consumers from Payments Scam Act (S. 4943, H.R. 9303)

Client expense: Not reported · Firm income: Not reported

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

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

CBAI Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau (CFPB) Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Sound Principles for Housing Government Sponsored Entity (GSE) Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Legitimate Bank Service Charges and Fees are not Exploitive and Junk Fees CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Realistic Perspective on Financial Inclusion CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks. Postal Banking Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking Public banking (i.e., publicly owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Federal Home Loan Banks in their Comprehensive Review Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. The results of the Comprehensive Review by the FHFA should not disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Rules and Implementation Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve - and must be closed. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. (House and Senate) Legislation and Regulation - S. 3502 (and Amendment 2358 to the NDA) - Homebuyers Privacy Protection Act (Senate) (All Sections) and H.R. 7297 - Trigger Leads Abatement Act (House) (All Sections) are bills to prohibit credit reporting agencies from providing a credit report not initiated by a consumer if the report is being provided on the basis that the consumer has had a credit inquiry regarding a home mortgage loan. This practice, known as producing a trigger lead, provides notice to other mortgage lenders that the consumer is seeking a mortgage loan. (Senate and House) H.R. 9303 and S. 4943 (All Sections) to protect consumers who are defrauded when they make payments (House and Senate) EGRPRA - Oral Comments During the EGRPRA Review concerning Anti Money Laundering, CTR and SAR reporting thresholds, Beneficial Ownership Interest reporting to FinCEN, and check fraud (FDIC, OCC, Federal Reserve) Letters - Comment Letter to the FHFA regarding Request for Input: Federal Home Loan Bank core mission and mission achievement (FHFA, FDIC, OCC, Federal Reserve) Comment Letter to the CFPB Regarding Proposed Rule - Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information [Debt] - Docket No. CFPB-2024-0023 and RIN 3170-AA54 (CFPB, FDIC, OCC, Federal Reserve) Action Alerts - Action Alert - Urge the Senate to pass S. 3502 (and Amendment 2358 to the NDA) - Homebuyers Privacy Protection Act (All Sections) a bill to prohibit credit reporting agencies from providing a credit report not initiated by a consumer if the report is being provided on the basis that the consumer has had a credit inquiry regarding a home mortgage loan. This practice, known as producing a trigger lead, provides notice to other mortgage lenders that the consumer is seeking a mortgage loan. (Senate) Miscellaneous - Deposit Check Fraud - The prompt and reasonable reimbursements for community banks from the largest banks for fraudulently altered return checks, and the largest banks opening fraudulent accounts into which fraud items are being deposited, including - joint supervisory guidance addressed to the largest banks for their apparent management and compliance lapses, enhanced supervision, regulation and enforcement against the largest banks for CDD and CIP compliance (OCC)

Issues relating to banking institutions impacting reform. Matters related to Community Reinvestment Act (CRA). Current Expected Credit Loss (CECL); Paycheck Protection Program. Matters relating to financial services regulatory reform, U.S. payments systems, anti-money laundering, beneficial ownership; nominations; and bank climate-related stress tests/scenario analysis. S. 3600 Strengthening American Cybersecurity Act; S.1838, Credit Card Competition Act of 2023; S.2760, Capping Credit Card Interest Rates Act; H.R. 7531, Secure Payments Act of 2024; S.3538, Close the Shadow Banking Loophole Act; S.2190, Recovering Executive Compensation Obtained from Unaccountable Practices Act of 2023 (RECOUP Act of 2023); and H.R. 9303, Protecting Consumers from Payment Scams Act.

Client expense: $360,000 · 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. 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.