Financial Reporting Threshold Modernization Act

H.R. 1799, Financial Reporting Threshold Modernization Act; provisions related to currency transaction reporting thresholds. Issues related to regulatory capital and liquidity.

Client expense: $950,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to money transfer services, de-risking and fintech; Issues related to consumer protection standards; Issues related to Dodd-Frank; Issues related to federal financial regulation; Issues related to digital assets; Issues related to improving scam prevention and fraud protection standards; H.R. 1799, Financial Reporting Threshold Modernization Act

Client expense: $90,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues pertaining to Banking Access; issues relating to banking in general; Payments Issues; issues pertaining to Deposit Insurance; issues pertaining to Data Privacy; issues pertaining to Bank Capital Standards; issues pertaining to BSA/AML; H.R. 1799, Financial Reporting Threshold Modernization Act, all provisions; H.R. 7035/S. 3623, Credit Card Competition Act of 2026, all provisions; H.R. 3633, Digital Asset Market Clarity Act of 2025, all provisions; H.R. 8395, PACE Act of 2026, all provisions; H.R. 8338, SAFER Act of 2026, all provisions.

Client expense: $640,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to money transmission services, federal financial regulation, consumer protection, the Bank Secrecy Act (BSA), and remittance consumer identification issues; S.3017, STREAMLINE Act; H.R.1799, Financial Reporting Threshold Modernization Act.

Client expense: Not reported · Firm income: $60,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Preserving credit union tax exemption; Tax Cuts and Jobs Act; HR 654 (move CFPB to appropriations); HJRes 59 (repeal overdraft rule); SJRes 18 (repeal overdraft rule); expansion of CFI definition under the FHLB; S. 522, Credit Union Board Modernization Act; S. 2019, the TRAPS Act (fraud prevention); Small Business Administration lending letter; the GENIUS Act (crypto & stablecoin); H.R. 507, the veterans member business lending act; HR 1799, the Financial Reporting Threshold Modernization Act; HR 4167/S. 3616, Expanding Access to Lending Options Act; S. 2545, the Expanding NCUA Liquidity Facility Enhancements Act; National Defense Authorization Act; Credit Card Competition Act (interchange); affordable housing; budget reconciliation; CU tax exemption; H.R. 7548/S. 3674, the SCAM Act; H.R. 933, the STOP Payments Fraud Act; H.R. 7647, the Minimizing Outdated Restrictions that Exclude (MORE) Opportunities for Homeownership Act; HR 10082, the Credit Union Investment Authority Act

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

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

Protect the credit union tax exemption Support legislation and regulation that advance credit unions and their over 146 million members Support regulatory relief for credit unions Support holistic evaluation of regulatory burden on credit unions Support modification of credit union loan maturity limits 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 modifying the credit union member business lending cap Support NCUAs existence as an independent regulator and insurer of credit unions Support assistance for minority depository institution credit unions Support regulatory relief for de novo credit unions Support harmonization of federal cyber incident notification standards Oppose Community Reinvestment Act requirements for credit unions Oppose legislative action to restrict credit union overdraft and courtesy pay programs Support regulatory framework for artificial intelligence that allows responsible innovation and recognizes credit unions compliance with existing regulations Support allowing use of artificial intelligence for regulatory reporting purposes Support mandatory arbitration agreements Oppose national interest rate cap Oppose national credit card interest rate cap Support expanded natural person and corporate credit union investment authority Support expanded credit union examination cycle Support increased examination transparency Support regulatory policies to promote innovation and access to credit Support Central Liquidity Facility and Community Development Revolving Loan Fund enhancements Oppose NCUA examination of credit union vendors Oppose National Credit Union Share Insurance Fund structural changes or premium assessment Support parity in deposit insurance coverage levels between credit unions and banks Oppose additional Call Report fields on loans to credit union officials and senior executive staff Oppose additional Call Report fields on maturity distribution of uninsured shares Oppose NCUA Call Report collection of overdraft and NSF fee revenue data Support modernization and simplification of Call Report form and instructions Oppose collection of vendor information in NCUA Credit Union Profile Oppose changes to NCUA collection forms outside rulemaking process Support NCUA review of normal operating level and methodology Oppose NCUA rule on succession planning Oppose excessive NCUA requirements for supervisory committee audits Support NCUA action to reduce scope of supervisory committee examination 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 action to clarify loan participation limits Support NCUA modification of low-income designation process Support expanding NCUA qualified charity definition Support allowing greater weighted average life for corporate credit unions financial assets Support extension of maturity limit for corporate credit union borrowing Support increased flexibility for advertising and notice of insured status Support increased compliance timeline for NCUA simplification of share insurance rule Support balanced implementation of debanking executive order Support increased NCUA efforts to promote credit union industry Support modernization and streamlining of NCUA operations Support NCUA supervisory flexibility for credit union shutdown assistance efforts Support NCUA and FFIEC action to modernize CAMELS rating system Support modernization of NCUA fidelity bond review requirements Support increased threshold for Depository Institution Management Interlocks Act major assets prohibition Support clarification of Federal Credit Union Act preemption of state interchange laws Support making CFPB subject to regular appropriations process Support increased CFPB budget transparency Support restructuring CFPB leadership to a bipartisan commission Support creation of a CFPB Inspector General Support reforms to CFPB Civil Investigative Demand process Support increasing and indexing asset thresholds for CFPB supervision of credit unions 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 use of cost-benefit analysis in rulemaking process 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 Oppose CFPB efforts to restrict information in credit reports Support CFPB engaging in ongoing retrospective review of past regulations Support CFPB consumer complaint database reforms Support CFPB no-action letter program with extended timeline and increased protection of sensitive strategic information Oppose expansion of consumer report and consumer reporting agency definitions under the Fair Credit Reporting Act/Regulation V Support consumer protection regulations for buy-now-pay-later loan providers Support inclusion of buy-now-pay-later loans in FHA underwriting Support CFPB use of Civil Penalty Fund for consumer financial education Support increase of Home Mortgage Disclosure Act reporting thresholds Support reforms to increase flexibility for TILA-RESPA Integrated Disclosure requirements Support inclusion of eligibility language for VA loans in FHA Informed Consumer Choice Disclosure Notice Support credit union access to universal service fund letters of credit program Support federal data privacy and security standard that exempts Gramm-Leach-Bliley Act covered institutions, preempts state laws, operates on an opt-out basis, recognizes the complexity of data deletion, and does not authorize private right of action Support increased transparency for fintech bank charter applications Support Treasury development of model forms and qualified vehicle list for auto loan interest deduction Support safe harbor for credit unions related to the auto loan interest deduction Support clarification of remittance transfer tax exemptions Support inclusion of credit unions in Trump Accounts program Oppose development of a central bank digital currency Support credit union access to Federal Reserve liquidity options Support gradual expansion of Fedwire and National Settlement Service operating hours with optional participation Oppose addition of fourth same-day ACH window Support expanded flexibility for accessing the Fed discount window and intraday credit Oppose expanded eligibility for Federal Reserve master account access Oppose Regulation II debit interchange fee cap Oppose Federal Reserve proposed rule on modifying Regulation II debit interchange cap Support improvements to the Federal Reserves Debit Card Issuer Survey Oppose legislative action to impose caps or restrictions on debit or credit interchange fees Oppose legislative action to prohibit the Federal Reserve from paying interest on reserves Support Federal Reserve action to coordinate regulatory guidance on penny circulation issues and management of penny supply Support continued offering of Federal Reserve check services 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 Support clarification of funds definition under Electronic Fund Transfer Act/Regulation E Support clarification of Electronic Fund Transfer Act/Regulation E treatment of digital assets Support increased flexibility for check holds and funds availability requirements Support transition to electronic payments for government payments Support clarification of Section 314(b) information sharing safe harbor for identifying and preventing payments fraud and additional flexibility for annual renewal requirement Support greater flexibility for credit unions to decline services with clear indicia of fraud or elder abuse Support parity for credit union provision of digital asset services and related regulations Prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products Support Treasury and NCUA action to implement regulatory framework for stablecoin issuance Support NCUAs role as primary regulator of credit unions stablecoin activities Oppose treating stablecoins or digital assets as federally insured Oppose payment of interest, yield, or rewards on stablecoin holdings Support digital assets guardrails to prevent deposit outflows Support clarifying credit unions authority to provide custodial services for their members Support safeguards for rehypothecation of digital assets Support reduced government-sponsored enterprises costs for credit union mortgages Support secondary mortgage market access for credit unions Support continued role for FHFA as an independent regulator Support credit union access to Federal Home Loan Bank system 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 Support Federal Home Loan Bank allocations to the Affordable Housing Program Support FinCEN implementation of the Corporate Transparency Act Support risk-based approach to anti-money laundering/countering financing of terrorism program requirements Support increasing Currency Transaction Report and Suspicious Activity Report filing thresholds Support streamlining Currency Transaction Report and Suspicious Activity Report forms Support increased inclusion of identifiable information in Section 314(a) information requests Support consistency between NCUA and FinCEN requirements on Bank Secrecy Act compliance Support FinCEN survey to accurately measure Bank Secrecy Act compliance costs Support DOD clarification of Military Lending Act and Servicemembers Civil Relief Act requirements Support standardized disclosures and financial literacy briefings for servicemembers Support credit union access to nominal leases on military installations Oppose nominal leases for banks on military installations Oppose legislative action on the Overseas Military Banking Program Oppose inclusion of interchange, interest rate cap, or fraud liability amendments in the National Defense Authorization Act Support inclusion of currency transaction report/suspicious activity report thresholds and veterans member business lending amendments in the National Defense Authorization Act Support federal share insurance for all credit unions acting as fiscal agents of the U.S. government Support role of Community Development Financial Institutions Fund in promoting economic growth and access to capital in underserved communities Support access to Community Development Financial Institutions Fund awards and technical assistance for credit unions Support Community Development Financial Institutions Fund bond guarantee program Support Community Development Financial Institutions Fund liquidity enhancement pilot program Support disbursement of all Community Development Financial Institution Fund appropriated award funding without additional barriers Support timely completion of Emergency Capital Investment Program disposition agreements Oppose reclassification of credit header information as a consumer report Oppose reliance on single source of documentation to determine instances of identity theft or coerced debt Oppose use of interim final rule to modify personal financial data rights requirements Support modification of Section 1033 rule to allow data providers to charge fees, remove prescriptive technology standards, and establish data privacy standards and allocation of liability Support modernization of e-signature requirements Support allowing electronic or documented oral credit card applications Support increased flexibility for disclosures Support rescission of CFPB payday lending rule payment provisions Support modification of FCC revocation of consent rule Support greater flexibility for FCC fraud alert exemption Support FCC efforts to combat illegal robocalls and robotexts Support uniform federal standards and increased federal preemption of state laws on interchange, data privacy, artificial intelligence, and elder financial abuse reporting Support federal safe harbor for provision of financial services to marijuana-related businesses that comply with state laws 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 nomination of John Crews as a member of the NCUA Board Support Credit Union Board Modernization Act (H.R. 975; S. 522) Support 1071 Repeal to Protect Small Business Lending Act (H.R. 976; S. 557) Support Making the CFPB Accountable to Small Businesses Act (H.R. 1606) Support Financial Integrity and Regulation Management Act (S. 875; H.R. 2702; Senate Amendment 3104) Support Fair Audits and Inspections for Regulators Exams Act (H.R. 940; S. 5335) Support Small LENDER Act (H.R. 941) Support Anti-CBDC Surveillance State Act (H.R. 1919; S. 1124) Support Veterans Member Business Loan Act (H.R. 507; S. 110; Senate Amendment 3776) Support Taking Account of Bureaucrats Spending Act (H.R. 654) Support Rectifying UDAAP Act (H.R. 1652) Support Civil Investigative Demand Reform Act (H.R. 1653) Support SECURE Notarization Act (H.R. 1777; S. 1561) Support Increasing Credit Union Lending for Business Growth Act (H.R. 1791) Support Financial Reporting Threshold Modernization Act (H.R. 1799; Amendment 715 to H.R. 3838) Support Home of Your Own Act (H.R. 2064) Support Homes for Every Local Protector, Educator, and Responder Act (H.R. 2094; S. 978) Support CFPB Dual Mandate and Economic Analysis Act (H.R. 2183) Support Transparency in CFPB Cost-Benefit Analysis Act (H.R. 2331) Support CFPB-IG Reform Act (H.R. 2513) Support Financial Institution Regulatory Tailoring Enhancement Act (H.R. 3230) Support Halting Uncertain Methods and Practices in Supervision Act (H.R. 3379) Support Taking Account of Institutions with Low Operation Risk Act (H.R. 3380) Support Bureau of Consumer Financial Protection Commission Act (H.R. 3445) Support Advancing the Mentor-Protege Program for Small Financial Institutions Act (H.R. 3709) Support Expanding Access to Lending Options Act (H.R. 4167; S. 3616) Support CDFI Bond Guarantee Program Improvement Act (S. 1880) Support Taskforce for Recognizing and Averting Payment Scams Act (H.R. 4936; S. 2019; Senate Amendment 3257) Support Capping Excessive Awarding of SBLC Entrants Act (H.R. 2987) Support Supervisory Modifications for Appropriate Risk-Based Testing Act (H.R. 4437) Support Stop Agency Fiat Enforcement Act (H.R. 4460) Support American Access to Banking Act (H.R. 4544) Support Protecting Access to Credit for Small Businesses Act (S. 2486) Support Business of Insurance Regulatory Reform Act (H.R. 4735; S. 2419) Support NCUA Central Liquidity Facility Enhancement Act (S. 2545, S. 3575; Senate Amendments 3722, 3834, 4384, 5882, 6180) Support CDFI Fund Transparency Act (S. 2704; Senate Amendments 3640, 3732; H.R. 7775) Support Supporting Upgraded Property Projects and Lending for Yards Act (H.R. 4568) Support Unleashing AI Innovation in Financial Services Act (H.R. 4801) Support AI Practices, Logistics, Actions, and Necessities Act (H.R. 2152) Support Streamlining Transaction Reporting and Ensuring Anti-Money Laundering Improvements for a New Era Act (S. 3017; Senate Amendment 6241) Support NFIP Continuation Act (H.R. 5577) Support 21st Century ROAD to Housing Act (H.R. 6644) Support Regulatory Efficiency, Verification, Itemization, and Enhanced Workflow Act (H.R. 6544) Support Community Bank Regulatory Tailoring Act (H.R. 7056) Support Close the Shadow Banking Loophole Act (S. 3734) Support American Lending Fairness Act (S. 3889; H.R. 7866) Support Community Bank Relief Act (S. 3849; H.R. 7484) Support Access to Fair Financing for Opportunity and Resilient Development Act (Senate Amendments 4354, 4394, 6101; S. 3940) Support Main Street Depositor Protection Act (S. 4198; Senate Amendment 6396) Support Growing Deposit Insurance for the Future Act (H.R. 8088) Support ESCRA Act (H.R. 306) Support Credit Access and Inclusion Act (H.R. 5402; S. 1465) Support FCRA Liability Harmonization Act (H.R. 5775) Support Guarding Unprotected Aging Retirees from Deception Act (H.R. 2978; S. 2544; Senate Amendment 6471) Support MORE Opportunities for Homeownership Act (H.R. 7647) Support Eliminating Fraud in the CFPBs Complaint Database Act (H.R. 7588) Support Fair Credit Reporting Reseller Accuracy Act (H.R. 8141) Support Bank Fraud Technology Advancement Act (H.R. 8671) Support STOP Payments Fraud Act (H.R. 9331) Support emergency transaction account guarantee legislation (H.R. 8075) Support Credit Union Investment Authority Act (H.R. 10082) Support CFPB Reform Act (H.R. 10184) Support inclusion of guidance on penny circulation and rounding in Common Cents Act (H.R. 3074, H.R. 10167; S. 1525) Support parity for credit unions and prohibition on stablecoin yield in Digital Asset Market Clarity Act (H.R. 3633) Support inclusion of additional credit union provisions in Main Street Capital Access Act (H.R. 6955) Oppose Repealing Big Brother Overreach Act (H.R. 425; S. 100) Oppose 10 Percent Credit Card Interest Rate Cap Act (H.R. 1944; S. 381; Senate Amendment 2239) Oppose Credit Card Competition Act (Senate Amendments 2229, 2230, 2345, 4305; S. 3623; H.R. 7035) Oppose commissary interchange fee study (Senate Amendment 3216) Oppose commissary coupon pilot program (Senate Amendments 5942, 6034) Oppose End the Feds Big Bank Bailout Act (S. 2113; Senate Amendment 3761) Oppose Credit Card Fairness Act (S. 3660) Oppose Strengthening Oversight for the Financial Sector Act (H.R. 10230) Oppose S.J.Res. 130, on CFPB overdraft circular Oppose S.J.Res. 132, on CFPB examinations for risks to servicemembers Oppose S.J.Res. 141, on deceptive collection of medical debt

Client expense: $1,060,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Executive Office of the President (EOP), 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), Justice, Dept of (DOJ), Natl Credit Union Administration (NCUA), Natl Economic Council (NEC), Office of Management & Budget (OMB), SENATE, Small Business Administration (SBA), Treasury, Dept of

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 standard as the financial service industry has to abide by and require that retailers notify credit unions sooner once a breach occurs. We support the introduction and passage of legislation that ensures all businesses, institutions and organizations that collect, collect, use or share personal data subject to national standards, to include language that preempts state requirements, among other things. Credit Unions are fighting a significant surge in fraud/scams that is costing American consumers billions annually. MCUL is educating lawmakers on the impact fraud is having on members and on credit unions. Credit unions are supporting three fraud related bills currently: H.R. 9331, the Strengthening Transaction Oversight and Preventing (STOP) Payments Fraud Act; S.2019/H.R. 4936, the Task Force for Recognizing and Averting Payment Scams (TRAPS) Act; and S.3774/H.R. 7548, the Safeguarding Consumers from Advertizing Misconduct (SCAM) Act. We are urging our delegation to support the legislation and call on leadership to pass the bills. 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 the Veterans Member Business Loan Act (S.210/H.R. 507) that would exempt credit union business loans to veterans from the member business lending cap and we are supporting the Credit Union Board Modernization Act (S.522/H.R. 975) which would afford federal credit unions flexibility with regard to how often their boards meet. 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 their 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 urging lawmakers in the House to co-sponsor and support H.R. 1799, the Financial Reporting Threshold Modernization Act which would increase the CTR threshold from $10k to $30k and index it going forward for inflation. It would also increase the SAR threshold from $5k to $10k. 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 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. Lastly, credit unions are non-for-profit member-owned financial institutions. 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.

Client expense: $40,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Preserving credit union tax exemption; Tax Cuts and Jobs Act; HR 654 (move CFPB to appropriations); HJRes 59 (repeal overdraft rule); SJRes 18 (repeal overdraft rule); expansion of CFI definition under the FHLB; S. 522, Credit Union Board Modernization Act; S. 2019, the TRAPS Act (fraud prevention); Small Business Administration lending letter; the GENIUS Act (crypto & stablecoin); H.R. 507, the veterans member business lending act; HR 1799, the Financial Reporting Threshold Modernization Act; HR 4167/S. 3616, Expanding Access to Lending Options Act; S. 2545, the Expanding NCUA Liquidity Facility Enhancements Act; National Defense Authorization Act; Credit Card Competition Act (interchange); affordable housing; budget reconciliation; CU tax exemption; H.R. 7548/S. 3674, the SCAM Act; H.R. 933, the STOP Payments Fraud Act; H.R. 7647, the Minimizing Outdated Restrictions that Exclude (MORE) Opportunities for Homeownership Act

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

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

Advocated for policies impacting the broader banking system, payments, and financial regulatory framework, including: Loan Maturity Modernization: Supported Scott Fitzgerald's H.R. 4167, the Expanding Access to Lending Options Act, which would provide the National Credit Union Administration (NCUA) Board with authority to extend federal credit union loan maturity limits beyond the current statutory cap. Advocacy emphasized increasing flexibility to offer more affordable loan terms, improve access to credit, and better meet the long-term borrowing needs of members while preserving safety and soundness. Federal Home Loan Bank (FHLB) Membership - MORE Opportunities Act, HR 7647: Supported legislation to expand access to Federal Home Loan Bank membership for credit unions, improving liquidity options and strengthening the ability of community financial institutions to support mortgage lending, affordable housing, and community development. 21st Century ROAD to Housing Act: Supported enactment of the bipartisan housing package, including provisions to address housing affordability, expand access to mortgage credit, modernize regulatory requirements, support the formation of new credit unions, establish mentorship opportunities between larger and smaller institutions, and enact the Credit Union Board Modernization Act. Credit Union Board Modernization Act, S.522, (CUBMA): Supported legislation reducing the required number of annual board meetings for federal credit unions from 12 to a minimum of six, providing regulatory relief while preserving safety and soundness standards. Bank Secrecy Act (BSA) / CTR Threshold Modernization: Supported legislation to update and index Currency Transaction Report (CTR) thresholds for inflation, including H.R. 1799, the Financial Reporting Threshold Modernization Act. Advocacy focused on reducing outdated regulatory burdens while maintaining effective anti-money laundering (AML) safeguards. Credit Card Interest Rate Caps: Opposed legislative proposals to impose a federal cap on credit card interest rates (e.g., 10 percent cap), citing concerns regarding reduced access to credit for higher-risk borrowers and disruption of risk-based pricing in unsecured lending. Interchange / Credit Card Routing Mandates: Opposed proposals to expand interchange routing requirements to credit cards, including the Credit Card Competition Act. Advocacy emphasized the role of interchange revenue in funding fraud prevention, cybersecurity, and consumer protections, as well as concerns about increased fraud risk and limited pass-through savings to consumers. Durbin Amendment Threshold Indexing: Supported legislative efforts to index the asset threshold for interchange regulation under the Durbin Amendment to inflation to preserve exemptions for smaller financial institutions, including S. 3849, the Community Bank Relief Act. Fraud Prevention and Scam Mitigation (TRAPS Act): Supported legislative efforts to address financial fraud and scams, including H.R. 4936 and S. 2019 (TRAPS Act). Advocacy included promoting interagency coordination, enhanced data-sharing, and tools for financial institutions to detect and prevent fraudulent activity. Consumer Financial Data Access (Section 1033): Engaged on rulemaking under Section 1033 of the Dodd-Frank Act regarding consumer financial data access. Advocacy focused on data security, appropriate liability allocation, and cost recovery for financial institutions providing third-party data access.

Client expense: $70,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), SENATE

Issues related to banking and credit unions; issues related to cannabis banking; issues related to deposit insurance; issues related to interchange; issues related to payment networks; issues related to consumer protection rules and regulations; issues related to rules and legislation affecting credit unions; issues related to lending programs and credit union operational flexibility; issues related to community development financial institutions; S. 303; S. 394; S. 401; S. 522; S. 919; S. 940; S. 1582; S. 1880; S. 2019; S. 2296; S. 2999; S. 3017; S. 3355; S. 3684; H.R. 654; H.R. 814; H.R. 975; H.R. 987; H.R. 1603; H.R. 1652; H.R 1791; H.R. 1799; H.R. 2392; H.R. 3633; H.R. 5900; H.R. 6644; H.R. 6936; H.R. 6955; H.R. 7056; H.R. 7148; H.R. 7548; H.R. 7647; H.R. 8087 H.R. 4167; S.J. Res. 18; H.J. Res. 50; H.J. Res. 59.

Client expense: $80,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to banking and credit unions; issues related to cannabis banking; issues related to deposit insurance; issues related to interchange; issues related to payment networks; issues related to consumer protection rules and regulations; issues related to rules and legislation affecting credit unions; issues related to lending programs and credit union operational flexibility; issues related to community development financial institutions; S. 303; S. 394; S. 401; S. 522; S. 919; S. 940; S. 1582; S. 1880; S. 2019; S. 2296; S. 2999; S. 3017; S. 3355; S. 3684; H.R. 654; H.R. 814; H.R. 975; H.R. 987; H.R. 1603; H.R. 1652; H.R 1791; H.R. 1799; H.R. 2392; H.R. 3633; H.R. 5900; H.R. 6644; H.R. 6936; H.R. 6955; H.R. 7056; H.R. 7148; H.R. 7548; H.R. 7647; H.R. 8087 H.R. 4167; S.J. Res. 18; H.J. Res. 50; H.J. Res. 59.

Client expense: $80,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 1013/S. 424, Retirement Fairness for Charities and Educational Institutions Act of 2025 H.R. 1109, Litigation Transparency Act of 2025, and potential amendments thereto H.R. 1190/S. 577, Expanding Access to Capital for Rural Job Creators Act H.R. 1467/S. 4055, Senior Security Act of 2026 H.R. 1469, Senior Security Act of 2025 H.R. 1799, Financial Reporting Threshold Modernization Act H.R. 2225/S. 1808, Access to Small Business Investor Capital Act H.R. 2441/S. 1877, Improving Disclosure for Investors Act of 2025 H.R. 2675/S. 3180, Protecting Our Courts From Foreign Manipulation Act of 2025 H.R. 3301, ELEVATE Act of 2025 H.R. 3339, Equal Opportunity for All Investors Act of 2025 H.R. 3343, Greenlighting Growth Act of 2025 H.R. 3351, Improving Access to Small Business Information Act H.R. 3352, HALOS Act of 2025 H.R. 3381, Encouraging Public Offerings Act of 2025 H.R. 3382/S. 2924, Small Entity Update Act H.R. 3383/S. 3671, Increasing Investor Opportunities Act H.R. 3394, Fair Investment Opportunities for Professional Experts Act H.R. 3512, Tackling Predatory Litigation Funding Act H.R. 3645, ACCESS Act of 2025 H.R. 3673, Small Business Investor Capital Access Act H.R. 3682/S. 3578, Financial Stability Oversight Council Improvement Act of 2025 H.R. 3959, Protecting Private Job Creators Act H.R. 4171, Small Entrepreneurs Empowerment and Development (SEED) Act of 2025 H.R. 4429, Developing and Empowering Our Aspiring Leaders (DEAL) Act H.R. 4430, Expanding WKSI Eligibility Act H.R. 4431, Improving Capital Formation for Newcomers (ICAN) Act H.R. 5437, Protection of Lawful Commerce in Stone Slab Products Act H.R. 5484, National Flood Insurance Program Reauthorization and Reform Act of 2025 H.R. 6955, Main Street Capital Access Act H.R. 7056, Community Bank Regulatory Tailoring Act H.R. 7085, To repeal certain disclosure requirements related to conflict minerals H.R. 7127, Restoring Secondary Market Trading Act H.R. 7128, Terrorism Risk Insurance Act of 2026 H.R. 8286, Protecting Americans' Retirement Savings From Politics Act H.R. 8338, Safeguarding Americans Fairly Earned Retirement Act of 2026 S. 985, PROTECT USA Act S. 2934, Protecting Americans from Russian Litigation Act of 2025, and potential litigation funding issues thereunder S. 3772, Export-Import Bank Reauthorization Act of 2026 S. 3826, Litigation Funding Transparency Act of 2026 Potential legislation similar to H.R. 448, Putting Investors First Act Potential legislation similar to H.R. 2590, Unlocking Capital for Small Business Act of 2023 Potential legislation similar to H.R. 2607, Improving Crowdfunding Opportunities Act, 2023 Potential legislation similar to H.R. 2622, to amend the Investment Advisers Act of 1940 to codify certain Securities and Exchange Commission no-action letters that exclude brokers and dealers compensated for certain research services from the definition of investment adviser Potential legislation similar to H.R. 2651, Regulation A+ Improvement Act of 2023 Potential legislation similar to H.R. 2799, the Investment Opportunity Expansion Act, 2023 Potential legislation similar to H.R. 4168/S. 2005, Mandatory Materiality Act Potential legislation similar to H.R. 4767, Protecting Americans Retirement Savings from Politics Act Potential legislation similar to H.R. 6623/S. 2068, Main Street Growth Act Potential legislation similar to S. 5139, Empowering Main Street in America Act (EMSAA) of 2024 Potential legislation to repeal the SECs Universal Proxy Rule of 2021 Potential legislation to amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to repeal certain rulemaking requirements Potential legislation, the Informed Investor Access Act, to amend the definition of accredited investor to include individuals receiving advice from certain professionals, and for other purposes Potential report language on FSOC/OFR stress test of nonbank financial institutions engaged in private credit Proposed amendment to H.R. 8800, the National Defense Authorization Act for FY 2027, to prohibit stock buybacks by certain defense contractors SEC Proposed Rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors (87 Fed. Reg. 21,334-21,473, April 11, 2022) SEC Proposed Rule on Publication or Submission of Quotations Without Specified Information (91 Fed. Reg. 13,243-13,263, March 19, 2026) SEC Proposed Rule on the Rescission of Climate-Related Disclosure Rules (91 Fed. Reg. 33,296-33,345, June 3, 2026) SEC Proposed Rule on Semiannual Reporting (91 Fed. Reg. 24,968-25,058, May 7, 2026) FSOC Proposed Interpretive Guidance on the Authority to Require Supervision and Regulation of Certain Nonbank Financial Companies (91 Fed. Reg. 15,551-15,566, March 30, 2026) Various issues relating to potential housing finance reform legislation; Basel III Endgame Rule; Export-Import Bank of the United States; implementation of the One Big Beautiful Bill Act, (P.L. 119-21); proxy process and shareholder proposal system overseen by SEC; antifraud accountability; reporting metrics of American companies under the EUs Corporate Sustainability Reporting Directive and Corporate Sustainability Due Diligence Directive; index fund passivity; reform to the function of the Public Company Accounting Oversight Board; rulemaking regarding corporate exemptions for shareholder proposals under SEC Rule 14a-8; rulemaking regarding reform to the proxy voting advice industry at the SEC; request for comment from SEC on potential revisions to executive compensation disclosure; request for comment from SEC on potential revisions to definition of Foreign Private Issuer; SEC Compliance and Disclosure Interpretations: Regulation 13D-G (February 11, 2025); potential policy affirming materiality as the standard for corporate disclosure at the SEC; Executive Order 14366, Protecting American Investors from Foreign-Owned and Politically-Motivated Proxy Advisors; Executive Order 14330, Democratizing Access to Alternative Assets for 401(K) Investors; SEC Staff Review ADI 2025-16 on Registered Closed-End Funds of Private Funds (August 15, 2025); acquired fund fees and expenses mandate under Rule 12d1-4 (impact of AFFE on BDCs and inclusion of alternative assets in 401(K)s); potential policy from SEC on electronic delivery of investor disclosure information; capital formation policy to expand access to capital for small businesses, strengthen public markets, and increase opportunities for investors; SEC proposal for an Innovation Exemption for Tokenized Securities; oversight issues and potential legislation on third party litigation funding, including its national security implications; insurance related litigation; oversight of the federal judiciary regarding third party litigation funding

Client expense: $16,950,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Trade Representative (USTR)

H.R. 3633, S. 3017, H.R. 1799, H.R. 2152, H.R. 4801, H.R. 8278 - Discussed margin issues and CCPs. Discussed issues related to bank structure, capital requirements, capital formation, market structure, market access and market liquidity. Discussed BSA/AML. Discussed AI, issues around financial technology policy and the regulatory perimeter. Discussed examination and enforcement issues. Discussed digital assets issues. Discussed issues related to establishing secure and resilient U.S. supply chains.

Client expense: $1,190,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

H.R. 478/S. 113, Promoting New Bank Formation Act S. 875/H.R. 2702, Financial Integrity and Regulation Management (FIRM) Act H.R. 1919/S. 1124, the Anti-CBDC Surveillance State Act H.R. 976/S. 557, the 1071 Repeal to Protect Small Business Lending Act H.R. 2392, the Stablecoin Transparency and Accountability for a Better Ledger Economy Act of 2025 (STABLE Act) S. 394/ S.919, Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS) S.3623/H.R.7035, Credit Card Competition Act of 2026 H.R. 1944/S. 381, the 10 Percent Credit Card Interest Rate Cap Act H.R. 654, the Taking Account of Bureaucrats Spending (TABS) Act of 2025 H.R. 987/S. 401, the Fair Access to Banking Act H.R. 1652, the Rectifying UDAAP Act H.R. 3445, the Bureau of Consumer Financial Protection Commission Act H.R. 1653, the CID Reform Act Business of Insurance Regulatory Reform Act H.R. 2513, CFPB-IG Reform Act H.R. 2183, the CFPB Dual Mandate and Economic Analysis Act H.R. 2331, the Transparency in CFPB Cost-Benefit Analysis Act H.R. 1606, the Making the CFPB Accountable to Small Business Act Cybersecurity Information Sharing Act Community Development Financial Institutions (CDFI) Fund Secure and Fair Enforcement (SAFE) Banking Act Regulatory Tailoring Community Reinvestment Act Deposit Insurance Reform S.4198/H.R.8087, the Main Street Depositor Protection Act National Bank Preemption H.R. 306, the Ending Scam Credit Repair Act Bank On Certification Program Central Bank Digital Currency Cryptocurrency Stablecoin Digital Assets Bank Capital Requirements/Basel Capital Proposal UDAAP Supervisory Policies and Adjudication Procedures Applying Community Reinvestment Act to credit unions Merchant Category Codes H.R. 1181, Protecting Privacy in Purchases Act H.R.1602, Financial Privacy Act of 2025 Foreign Affiliate Sharing Pilot Program Extension Act Financial Innovation and Technology for the 21st Century Act H.R.2885, Bank Loan Privacy Act H.R. 941, Small Lender 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 Artificial Intelligence Risk Management, Regulation, and Innovation CDFI Certification & Funding Federal Reserve Discount Window and Emergency Lending Authority Tokenization of Assets Fraud Issues Peer-To-Peer Payment Fraud Financial Data Transparency Act Rulemaking FDIC Brokered Deposit Proposal H.R. 3633, the Digital Asset Market Clarity (CLARITY) Act of 2025 H.R.1900 - Bank Failure Prevention Act of 2025 H.R.3230 - Financial Institution Regulatory Tailoring Enhancement Act H.R.8287 - Stress Testing Accountability and Transparency Act H.R. 2835, the Small Bank Holding Company Relief Act H.R. 3709, the Advancing the Mentor-Protege Program for Small Financial Institutions Act H.R. 3716, the Systemic Risk Authority Transparency Act H.R. 940, the Fair Audits and Inspections for Regulators' (FAIR) Exams Act H.R. 3379, the Halting Uncertain Methods and Practices in Supervision (HUMPS) Act of 2025 H.R. 3380, the Taking Account of Institutions with Low Operation Risk (TAILOR) Act of 2025 S.2019 - Task Force for Recognizing and Averting Payments Scams (TRAPS) Act H.R. 3390, the Bringing the Discount Window into the 21st Century Act H.R. 4460, the Stop Agency Fiat Enforcement of Guidance (SAFE Guidance) Act H.R. 3446, the FDIC Board Accountability Act H.R. 4544, The American Access to Banking Act H.R. 4478, the Tailored Regulatory Updates for Supervisory Testing Act of 2025 (TRUST Act) H.R. 4437, the Supervisory Modifications for Appropriate Risk-Based Testing Act of 2025 (SMART Act) H.R. 5270, the Stress Testing Accountability and Transparency Act H.R. 5276, the Community Bank Leverage Improvement and Flexibility for Transparency (Community Bank LIFT) Act H.R. 5291, the Merchant Banking Modernization Act H.R. 5262, the Bank Competition Modernization Act Legislation to support Minority Depository Institutions H.R. 6553, the Tailoring and Indexing Enhanced Regulations (TIER) Act H.R. 6554, the Community Bank Representation Act H.R. 6536, Rural Depositories Revitalization Study Act H.R. 6551, the New Bank Application Numbers Knowledge Act (New BANK) Act H.R. 6546, Merger Process Review Act H.R. 6570, the Merger Agreement Approvals Clarity and Predictability Act H.R. 6544, The Regulatory Efficiency, Verification, Itemization, and Enhanced Workflow (REVIEW) Act H.R. 6550, the American Financial Institution Regulatory Sovereignty and Transparency (American FIRST) Act H.R. 6555, the Enhancing Bank Resolution Participation Act Ensuring Fair Access to Banking Act H.R. 6955, the Main Street Capital Access Act H.R. 7056, the Community Bank Regulatory Tailoring Act S.3940, the Access to Fair Financing for Opportunity and Resilient Development (AFFORD) Act S. 3017, the STREAMLINE Act H.R. 1799, the Financial Reporting Threshold Modernization Act H.R. 8278, Fostering the Use of Technology to Uphold Regulatory Effectiveness in Supervision (FUTURES) Act H.R. 9331, the Strengthening Transaction Oversight Preventing (STOP) Payments Fraud Act H.R. 9471/S. 4942, the Secure and Fair Enforcement Banking Act (SAFE Banking Act) of 2026 H.R. 8395, the Payments Access and Consumer Efficiency (PACE) Act

Client expense: $3,510,000 · Firm income: Not reported

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

Issues pertaining to Banking Access; issues relating to banking in general; Payments Issues; issues pertaining to Deposit Insurance; issues pertaining to Data Privacy; issues pertaining to Bank Capital Standards; issues pertaining to BSA/AML; H.R. 1799, Financial Reporting Threshold Modernization Act, all provisions; H.R. 7035/S. 3623, Credit Card Competition Act of 2026, all provisions; H.R. 2392, STABLE Act of 2025, all provisions; S. 394, GENIUS Act of 2025, all provisions; H.R. 3633, Digital Asset Market Clarity Act of 2025, all provisions. H.R. 8395, PACE Act of 2026, all provisions.

Client expense: $720,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 1799, Financial Reporting Threshold Modernization Act; provisions related to currency transaction reporting thresholds. S. 2999, Main Street Depositor Protection Act; provisions related to deposit insurance reform. S. 4198, Main Street Depositor Protection Act; provisions related to deposit insurance reform. Issues related to regulatory capital and liquidity.

Client expense: $290,000 · 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 146 million members Support regulatory relief for credit unions Support holistic evaluation of regulatory burden on credit unions Support modification of credit union loan maturity limits 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 modifying the credit union member business lending cap Support NCUAs existence as an independent regulator and insurer of credit unions Support assistance for minority depository institution credit unions Support regulatory relief for de novo credit unions Support harmonization of federal cyber incident notification standards Oppose Community Reinvestment Act requirements for credit unions Oppose legislative action to restrict credit union overdraft and courtesy pay programs Support regulatory framework for artificial intelligence that allows responsible innovation and recognizes credit unions compliance with existing regulations Support allowing use of artificial intelligence for regulatory reporting purposes Support mandatory arbitration agreements Oppose national interest rate cap Oppose national credit card interest rate cap Support expanded natural person and corporate credit union investment authority Support expanded credit union examination cycle Support increased examination transparency Support regulatory policies to promote innovation and access to credit Support Central Liquidity Facility and Community Development Revolving Loan Fund enhancements Oppose NCUA examination of credit union vendors Oppose National Credit Union Share Insurance Fund structural changes or premium assessment Support parity in deposit insurance coverage levels between credit unions and banks Oppose additional Call Report fields on loans to credit union officials and senior executive staff Oppose additional Call Report fields on maturity distribution of uninsured shares Oppose making changes to Call Report requirements without using notice-and-comment process Oppose NCUA Call Report collection of overdraft and NSF fee revenue data Support modernization and simplification of Call Report form and instructions Support rescission of NCUA overdraft and NSF fee guidance Oppose collection of vendor information in NCUA Credit Union Profile Oppose changes to NCUA collection forms outside rulemaking process Support NCUA review of normal operating level and methodology Support NCUA action to permit credit union reimbursement of dependent care expenses for federal credit union official duties Oppose NCUA rule on succession planning Support modification of NCUA record retention requirements Oppose excessive NCUA requirements for supervisory committee audits Support NCUA action to reduce scope of supervisory committee examination 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 action to clarify loan participation limits Support NCUA modification of low-income designation process Support expanding NCUA qualified charity definition Support allowing greater weighted average life for corporate credit unions financial assets Support extension of maturity limit for corporate credit union borrowing Support increased flexibility for advertising and notice of insured status Support increased compliance timeline for NCUA simplification of share insurance rule Support removing reputational risk as a component of credit union examinations Support balanced implementation of debanking executive order Support increased NCUA efforts to promote credit union industry Support modernization and streamlining of NCUA operations Support NCUA supervisory flexibility for credit union shutdown assistance efforts Support NCUA action to modernize CAMELS rating system Support modernization of NCUA fidelity bond review requirements Support making CFPB subject to regular appropriations process Support increased CFPB budget transparency Support restructuring CFPB leadership to a bipartisan commission Support creation of a CFPB Inspector General Support reforms to CFPB Civil Investigative Demand process Support increasing asset thresholds for CFPB supervision of credit unions 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 use of cost-benefit analysis in rulemaking process 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 Oppose CFPB efforts to restrict information in credit reports Support CFPB engaging in ongoing retrospective review of past regulations Support CFPB consumer complaint database reforms Support CFPB no-action letter program with extended timeline and increased protection of sensitive strategic information Oppose expansion of consumer report and consumer reporting agency definitions under the Fair Credit Reporting Act/Regulation V Support consumer protection regulations for buy-now-pay-later loan providers Support inclusion of buy-now-pay-later loans in FHA underwriting Support CFPB use of Civil Penalty Fund for consumer financial education Support increase of Home Mortgage Disclosure Act reporting thresholds Support removal of disparate impact analysis from Regulation B and modification of discouragement standard Support credit union access to universal service fund letters of credit program Support recognition of unique credit union structure in Financial Data Transparency Act joint data standards Support federal data privacy and security standard that exempts Gramm-Leach-Bliley Act covered institutions, preempts state laws, operates on an opt-out basis, recognizes the complexity of data deletion, and does not authorize private right of action Support increased transparency for fintech bank charter applications Support Treasury development of model forms and qualified vehicle list for auto loan interest deduction Support safe harbor for credit unions related to the auto loan interest deduction Support clarification of remittance transfer tax exemptions Support inclusion of credit unions in Trump Accounts program Oppose development of a central bank digital currency Support credit union access to Federal Reserve liquidity options Support gradual expansion of Fedwire and National Settlement Service operating hours with optional participation Oppose addition of fourth same-day ACH window Support expanded flexibility for accessing the Fed discount window and intraday credit Oppose expanded eligibility for Federal Reserve master account access Oppose Regulation II debit interchange fee cap Oppose Federal Reserve proposed rule on modifying Regulation II debit interchange cap Support improvements to the Federal Reserves Debit Card Issuer Survey Oppose legislative action to impose caps or restrictions on debit or credit interchange fees Oppose legislative action to prohibit the Federal Reserve from paying interest on reserves Support Federal Reserve action to coordinate regulatory guidance on penny circulation issues and management of penny supply Support continued offering of Federal Reserve check services 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 Support clarification of funds definition under Electronic Fund Transfer Act/Regulation E Support clarification of Electronic Fund Transfer Act/Regulation E treatment of digital assets Support increased flexibility for check holds and funds availability requirements Support transition to electronic payments for government payments Support consumer education on transition to electronic payments Support clarification of Section 314(b) information sharing safe harbor for identifying and preventing payments fraud Support greater flexibility for credit unions to decline services with clear indica of fraud or elder abuse 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 Treasury and NCUA action to implement regulatory framework for stablecoin issuance Support parity for credit unions related to stablecoin regulation Support NCUAs role as primary regulator of credit unions stablecoin activities Oppose treating stablecoins or digital assets as federally insured Oppose payment of interest, yield, or rewards on stablecoin holdings Support digital assets guardrails to prevent deposit outflows Support clarifying credit unions authority to provide custodial services for their members Support safeguards for rehypothecation of digital assets Support reduced government-sponsored enterprises costs for credit union mortgages Support secondary mortgage market access for credit unions Support continued role for FHFA as an independent regulator Support credit union access to Federal Home Loan Bank system 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 Support Federal Home Loan Bank allocations to the Affordable Housing Program Support FinCEN implementation of the Corporate Transparency Act Support additional time to implement anti-money laundering/countering financing of terrorism program changes and publication of guidance Support increasing Currency Transaction Report and Suspicious Activity Report filing thresholds Support streamlining Currency Transaction Report and Suspicious Activity Report forms Support increased inclusion of identifiable information in Section 314(a) information requests Support consistency between NCUA and FinCEN requirements on Bank Secrecy Act compliance Support FinCEN survey to accurately measure Bank Secrecy Act compliance costs Support DOD clarification of Military Lending Act and Servicemembers Civil Relief Act requirements Support standardized disclosures and financial literacy briefings for servicemembers Support credit union access to nominal leases on military installations Oppose nominal leases for banks on military installations Oppose legislative action on the Overseas Military Banking Program Oppose inclusion of interchange, interest rate cap, or fraud liability amendments in the National Defense Authorization Act Support inclusion of currency transaction report/suspicious activity report thresholds and veterans member business lending amendments in the National Defense Authorization Act Support federal share insurance for all credit unions acting as fiscal agents of the U.S. government Support role of Community Development Financial Institutions Fund in promoting economic growth and access to capital in underserved communities Support access to Community Development Financial Institutions Fund awards and technical assistance for credit unions Support Community Development Financial Institutions Fund bond guarantee program Support Community Development Financial Institutions Fund liquidity enhancement pilot program Support disbursement of all Community Development Financial Institution Fund appropriated award funding without additional barriers Support timely completion of Emergency Capital Investment Program disposition agreements Oppose reclassification of credit header information as a consumer report Oppose reliance on single source of documentation to determine instances of identity theft or coerced debt Oppose use of interim final rule to modify personal financial data rights requirements Support modification of Section 1033 rule to allow data providers to charge fees, remove prescriptive technology standards, and establish data privacy standards and allocation of liability Support increased reporting and small business revenue threshold and elimination of discretionary data points collection in revised Section 1071 rule Support modernization of e-signature requirements Support allowing electronic or documented oral credit card applications Support increased flexibility for disclosures Support rescission of CFPB payday lending rule payment provisions Support modification of FCC revocation of consent rule Support greater flexibility for FCC fraud alert exemption Support uniform federal standards and increased federal preemption of state laws on interchange, data privacy, artificial intelligence, and elder financial abuse reporting Support federal safe harbor for provision of financial services to marijuana-related businesses that comply with state laws 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 nomination of John Crews as a member of the NCUA Board Support Credit Union Board Modernization Act (H.R. 975; S. 522) Support 1071 Repeal to Protect Small Business Lending Act (H.R. 976; S. 557) Support Making the CFPB Accountable to Small Businesses Act (H.R. 1606) Support Financial Integrity and Regulation Management Act (S. 875; H.R. 2702; Senate Amendment 3104) Support Fair Audits and Inspections for Regulators Act (H.R. 940) Support Small LENDER Act (H.R. 941) Support Anti-CBDC Surveillance State Act (H.R. 1919; S. 1124) Support Veterans Member Business Loan Act (H.R. 507; S. 110; Senate Amendment 3776) Support Taking Account of Bureaucrats Spending Act (H.R. 654) Support Rectifying UDAAP Act (H.R. 1652) Support Civil Investigative Demand Reform Act (H.R. 1653) Support SECURE Notarization Act (H.R. 1777; S. 1561) Support Increasing Credit Union Lending for Business Growth Act (H.R. 1791) Support Financial Reporting Threshold Modernization Act (H.R. 1799; Amendment 715 to H.R. 3838) Support Home of Your Own Act (H.R. 2064) Support Homes for Every Local Protector, Educator, and Responder Act (H.R. 2094; S. 978) Support CFPB Dual Mandate and Economic Analysis Act (H.R. 2183) Support Transparency in CFPB Cost-Benefit Analysis Act (H.R. 2331) Support CFPB-IG Reform Act (H.R. 2513) Support Homebuyers Privacy Protection Act (H.R. 2808; S. 1467) Support Financial Institution Regulatory Tailoring Enhancement Act (H.R. 3230) Support Halting Uncertain Methods and Practices in Supervision Act (H.R. 3379) Support Taking Account of Institutions with Low Operation Risk Act (H.R. 3380) Support Bureau of Consumer Financial Protection Commission Act (H.R. 3445) Support Advancing the Mentor-Protege Program for Small Financial Institutions Act (H.R. 3709) Support Expanding Access to Lending Options Act (H.R. 4167) Support CDFI Bond Guarantee Program Improvement Act (S. 1880) Support Taskforce for Recognizing and Averting Payment Scams Act (H.R. 4936; S. 2019; Senate Amendment 3257) Support Capping Excessive Awarding of SBLC Entrants Act (H.R. 2987) Support Expanding Access to Lending Options Act (H.R. 4167) Support Supervisory Modifications for Appropriate Risk-Based Testing Act (H.R. 4437) Support Stop Agency Fiat Enforcement Act (H.R. 4460) Support American Access to Banking Act (H.R. 4544) Support Protecting Access to Credit for Small Businesses Act (S. 2486) Support Business of Insurance Regulatory Reform Act (H.R. 4735; S. 2419) Support NCUA Central Liquidity Facility Enhancement Act (S. 2545, S. 3575; Senate Amendments 3722, 3834, 4384, 5882, 6180) Support CDFI Fund Transparency Act (S. 2704; Senate Amendments 3640, 3732) Support Supporting Upgraded Property Projects and Lending for Yards Act (H.R. 4568) Support Unleashing AI Innovation in Financial Services Act (H.R. 4801) Support AI Practices, Logistics, Actions, and Necessities Act (H.R. 2152) Support Streamlining Transaction Reporting and Ensuring Anti-Money Laundering Improvements for a New Era Act (S. 3017; Senate Amendment 6241) Support NFIP Continuation Act (H.R. 5577) Support 21st Century ROAD to Housing Act (H.R. 6644) Support Regulatory Efficiency, Verification, Itemization, and Enhanced Workflow Act (H.R. 6544) Support Community Bank Regulatory Tailoring Act (H.R. 7056) Support Close the Shadow Banking Loophole Act (S. 3734) Support American Lending Fairness Act (S. 3889; H.R. 7866) Support Community Bank Relief Act (S. 3849; H.R. 7484) Support Access to Fair Financing for Opportunity and Resilient Development Act (Senate Amendments 4354, 4394, 6101; S. 3940) Support Growing Deposit Insurance for the Future Act (H.R. 8088) Support ESCRA Act (H.R. 306) Support Credit Access and Inclusion Act (H.R. 5402; S. 1465) Support FCRA Liability Harmonization Act (H.R. 5775) Support Guarding Unprotected Aging Retirees from Deception Act (H.R. 2978; S. 2544; Senate Amendment 6471) Support Eliminating Fraud in the CFPBs Complaint Database Act (H.R. 7588) Support Fair Credit Reporting Reseller Accuracy Act (H.R. 8141) Support Bank Fraud Technology Advancement Act (H.R. 8671) Support STOP Payments Fraud Act (H.R. 9331) Support emergency transaction account guarantee legislation (H.R. 8075) Support inclusion of guidance on penny circulation and rounding in Common Cents Act (H.R. 3074) Support parity for credit unions and prohibition on stablecoin yield in Digital Asset Market Clarity Act (H.R. 3633) Support modification of Section 705 in Renewing Opportunity in the American Dream to Housing Act (S. 2651) Support inclusion of credit union parity provisions in Main Street Capital Access Act (H.R. 6955) Oppose Repealing Big Brother Overreach Act (H.R. 425; S. 100) Oppose 10 Percent Credit Card Interest Rate Cap Act (H.R. 1944; S. 381; Senate Amendment 2239) Oppose Credit Card Competition Act (Senate Amendments 2229, 2230, 2345, 4305; S. 3623; H.R. 7035) Oppose commissary interchange fee study (Senate Amendment 3216) Oppose commissary coupon pilot program (Senate Amendments 5942, 6034) Oppose End the Feds Big Bank Bailout Act (S. 2113; Senate Amendment 3761) Oppose Credit Card Fairness Act (S. 3660) Oppose S.J.Res. 130, on CFPB overdraft circular Oppose S.J.Res. 132, on CFPB examinations for risks to servicemembers Oppose S.J.Res. 141, on deceptive collection of medical debt

Client expense: $1,290,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Executive Office of the President (EOP), 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), Justice, Dept of (DOJ), Natl Credit Union Administration (NCUA), Natl Economic Council (NEC), Office of Management & Budget (OMB), SENATE, Small Business Administration (SBA), Treasury, Dept of

Issues related to money transmission services, federal financial regulation, consumer protection, the Bank Secrecy Act (BSA), and remittance consumer identification issues; S.3017, STREAMLINE Act; H.R.1799, Financial Reporting Threshold Modernization Act.

Client expense: Not reported · Firm income: $60,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to money transfer services, de-risking and fintech; Issues related to consumer protection standards; Issues related to Dodd-Frank; Issues related to federal financial regulation; Issues related to digital assets; Issues related to improving scam prevention and fraud protection standards; H.R. 1799, Financial Reporting Threshold Modernization Act

Client expense: $90,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 1013/S. 424, Retirement Fairness for Charities and Educational Institutions Act of 2025 H.R. 1109, Litigation Transparency Act of 2025, and potential amendments thereto H.R. 1190/S. 577, Expanding Access to Capital for Rural Job Creators Act H.R. 1799, Financial Reporting Threshold Modernization Act H.R. 2225/S. 1808, Access to Small Business Investor Capital Act H.R. 2441/S. 1877, Improving Disclosure for Investors Act of 2025 H.R. 2675/S. 3180, Protecting Our Courts From Foreign Manipulation Act of 2025 H.R. 3301, ELEVATE Act of 2025 H.R. 3339, Equal Opportunity for All Investors Act of 2025 H.R. 3343, Greenlighting Growth Act of 2025 H.R. 3351, Improving Access to Small Business Information Act H.R. 3352, HALOS Act of 2025 H.R. 3381, Encouraging Public Offerings Act of 2025 H.R. 3382/S. 2924, Small Entity Update Act H.R. 3383/S. 3671, Increasing Investor Opportunities Act H.R. 3394, Fair Investment Opportunities for Professional Experts Act H.R. 3645, ACCESS Act of 2025 H.R. 3673, Small Business Investor Capital Access Act H.R. 3682/S. 3578, Financial Stability Oversight Council Improvement Act of 2025 H.R. 3959, Protecting Private Job Creators Act H.R. 4171, Small Entrepreneurs Empowerment and Development (SEED) Act of 2025 H.R. 4429, Developing and Empowering Our Aspiring Leaders (DEAL) Act H.R. 4430, Expanding WKSI Eligibility Act H.R. 4431, Improving Capital Formation for Newcomers (ICAN) Act H.R. 6955, Main Street Capital Access Act H.R. 7056, Community Bank Regulatory Tailoring Act H.R. 7085, to repeal certain disclosure requirements related to conflict minerals H.R. 7127, Restoring Secondary Market Trading Act H.R. 7128, Terrorism Risk Insurance Act of 2026 S. 985, PROTECT USA Act S. 2934, Protecting Americans from Russian Litigation Act of 2025, and potential litigation funding issues thereunder S. 3826, Litigation Funding Transparency Act of 2026 Potential legislation similar to H.R. 448, Putting Investors First Act Potential legislation similar to H.R. 2590, Unlocking Capital for Small Business Act of 2023 Potential legislation similar to H.R. 2607, Improving Crowdfunding Opportunities Act, 2023 Potential legislation similar to H.R. 2622, to amend the Investment Advisers Act of 1940 to codify certain Securities and Exchange Commission no-action letters that exclude brokers and dealers compensated for certain research services from the definition of investment adviser Potential legislation similar to H.R. 2651, Regulation A+ Improvement Act of 2023 Potential legislation similar to H.R. 2799, the Investment Opportunity Expansion Act, 2023 Potential legislation similar to H.R. 4168/S. 2005, Mandatory Materiality Act Potential legislation similar to H.R. 4767, Protecting Americans Retirement Savings from Politics Act Potential legislation similar to H.R. 6623/S. 2068, Main Street Growth Act Potential legislation similar to S. 5139, Empowering Main Street in America Act (EMSAA) of 2024 Potential legislation to repeal the SECs Universal Proxy Rule of 2021 Potential legislation to amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to repeal certain rulemaking requirements Potential legislation to prevent the premature seizure of an individuals securities, digital assets, or investment accounts in the custody of a financial institution under State escheatment laws, and for other purposes Potential legislation to amend the definition of accredited investor to include individuals receiving advice from certain professionals, and for other purposes SEC Proposed Rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors (87 Fed. Reg. 21,334-21,473, April 11, 2022) Various issues relating to potential housing finance reform legislation; Basel III Endgame Rule; issues related to the Export-Import Bank of the United States; European Unions (EU) Corporate Sustainability Due Diligence Directive (CSDDD); reauthorization of the U.S. International Development Finance Corporation; implementation of the One Big Beautiful Bill Act, (P.L. 119-21); implementation of Disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Overdraft Lending: Very Large Financial Institutions" (P.L. No: 119-10); implementation of A joint resolution disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications" (P.L. No: 119-11); proxy process and shareholder proposal system overseen by SEC; proxy process, proxy advisory firms, and other related aspects of corporate governance; FSOC Nonbank Guidance - request to restore the 2019 Guidance (July 14, 2025, letter to Treasury); reporting metrics of American companies under the EUs Corporate Sustainability Reporting Directive and Corporate Sustainability Due Diligence Directive; index fund passivity; reform to the function of the Public Company Accounting Oversight Board; rulemaking regarding corporate exemptions for shareholder proposals under SEC Rule 14a-8; rulemaking regarding reform to the proxy voting advice industry at the SEC; request for comment from SEC on potential revisions to executive compensation disclosure; request for comment from SEC on potential revisions to definition of Foreign Private Issuer; SEC Compliance and Disclosure Interpretations: Regulation 13D-G (February 11, 2025); potential policy affirming materiality as the standard for corporate disclosure at the SEC; Executive Order 14366, Protecting American Investors from Foreign-Owned and Politically-Motivated Proxy Advisors; Executive Order 14330, Democratizing Access to Alternative Assets for 401(K) Investors; SEC Staff Review ADI 2025-16 on Registered Closed-End Funds of Private Funds (August 15, 2025); acquired fund fees and expenses mandate under Rule 12d1-4 (impact of AFFE on BDCs and inclusion of alternative assets in 401(K)s); potential policy from SEC on electronic delivery of investor disclosure information; capital formation policy to expand access to capital for small businesses, strengthen public markets, and increase opportunities for investors; oversight issues and potential legislation on third party litigation funding, including its national security implications; insurance related litigation; oversight of the federal judiciary regarding third party litigation funding

Client expense: $19,750,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Labor, Dept of (DOL), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Trade Representative (USTR)

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 standard as the financial service industry has to abide by and require that retailers notify credit unions sooner once a breach occurs. We support the introduction and passage of legislation that ensures all businesses, institutions and organizations that collect, collect, use or share personal data 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 the Veterans Member Business Loan Act (S.210/H.R. 507) that would exempt credit union business loans to veterans from the member business lending cap and we are supporting the Credit Union Board Modernization Act (S.522/H.R. 975) which would afford federal credit unions flexibility with regard to how often their boards meet. 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 their 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 urging lawmakers in the House to co-sponsor and support H.R. 1799, the Financial Reporting Threshold Modernization Act which would increase the CTR threshold from $10k to $30k and index it going forward for inflation. It would also increase the SAR threshold from $5k to $10k. 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 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. Lastly, credit unions are non-for-profit member-owned financial institutions. 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.

Client expense: $40,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to banking and credit unions; issues related to cannabis banking; issues related to deposit insurance; issues related to interchange; issues related to payment networks; issues related to consumer protection rules and regulations; issues related to rules and legislation affecting credit unions; issues related to lending programs and credit union operational flexibility; issues related to community development financial institutions; S. 303; S. 394; S. 401; S. 522; S. 919; S. 940; S. 1582; S. 1880; S. 2019; S. 2296; S. 2999; S. 3017; H.R. 654; H.R. 814; H.R. 975; H.R. 987; H.R. 1603; H.R. 1652; H.R 1791; H.R. 1799; H.R. 2392; H.R. 3633; H.R. 6644; H.R. 6936; H.R. 6955; H.R. 7056; H.R. 7148; H.R. 7548; H.R. 7647; H.R. 8087 H.R. 4167; S.J. Res. 18; H.J. Res. 50; H.J. Res. 59.

Client expense: $90,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to banking and credit unions; issues related to cannabis banking; issues related to deposit insurance; issues related to interchange; issues related to payment networks; issues related to consumer protection rules and regulations; issues related to rules and legislation affecting credit unions; issues related to lending programs and credit union operational flexibility; issues related to community development financial institutions; S. 303; S. 394; S. 401; S. 522; S. 919; S. 940; S. 1582; S. 1880; S. 2019; S. 2296; S. 2999; S. 3017; H.R. 654; H.R. 814; H.R. 975; H.R. 987; H.R. 1603; H.R. 1652; H.R 1791; H.R. 1799; H.R. 2392; H.R. 3633; H.R. 6644; H.R. 6936; H.R. 6955; H.R. 7056; H.R. 7148; H.R. 7548; H.R. 7647; H.R. 8087 H.R. 4167; S.J. Res. 18; H.J. Res. 50; H.J. Res. 59.

Client expense: $90,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 478/S. 113, Promoting New Bank Formation Act S. 875/H.R. 2702, Financial Integrity and Regulation Management (FIRM) Act H.R. 1919/S. 1124, the Anti-CBDC Surveillance State Act H.R. 976/S. 557, the 1071 Repeal to Protect Small Business Lending Act H.R. 2392, the Stablecoin Transparency and Accountability for a Better Ledger Economy Act of 2025 (STABLE Act) S. 394/ S.919, Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS) S.3623/H.R.7035, Credit Card Competition Act of 2026 H.R. 1944/S. 381, the 10 Percent Credit Card Interest Rate Cap Act H.R. 654, the Taking Account of Bureaucrats Spending (TABS) Act of 2025 H.R. 987/S. 401, the Fair Access to Banking Act H.R. 1652, the Rectifying UDAAP Act H.R. 3445, the Bureau of Consumer Financial Protection Commission Act H.R. 1653, the CID Reform Act Business of Insurance Regulatory Reform Act H.R. 2513, CFPB-IG Reform Act H.R. 2183, the CFPB Dual Mandate and Economic Analysis Act H.R. 2331, the Transparency in CFPB Cost-Benefit Analysis Act H.R. 1606, the Making the CFPB Accountable to Small Business Act Cybersecurity Information Sharing Act Community Development Financial Institutions (CDFI) Fund Secure and Fair Enforcement (SAFE) Banking Act Regulatory Tailoring Community Reinvestment Act Deposit Insurance Reform S.4198/H.R.8087, the Main Street Depositor Protection Act National Bank Preemption H.R. 306, the Ending Scam Credit Repair Act Bank On Certification Program Central Bank Digital Currency Cryptocurrency Stablecoin Digital Assets Bank Capital Requirements/Basel Capital Proposal UDAAP Supervisory Policies and Adjudication Procedures Applying Community Reinvestment Act to credit unions Merchant Category Codes H.R. 1181, Protecting Privacy in Purchases Act H.R.1602, Financial Privacy Act of 2025 Foreign Affiliate Sharing Pilot Program Extension Act Financial Innovation and Technology for the 21st Century Act H.R.2885, Bank Loan Privacy Act H.R. 941, Small Lender 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 Artificial Intelligence Risk Management, Regulation, and Innovation CDFI Certification & Funding Federal Reserve Discount Window and Emergency Lending Authority Tokenization of Assets Fraud Issues Peer-To-Peer Payment Fraud Financial Data Transparency Act Rulemaking FDIC Brokered Deposit Proposal H.R. 3633, the Digital Asset Market Clarity (CLARITY) Act of 2025 H.R.1900 - Bank Failure Prevention Act of 2025 H.R.3230 - Financial Institution Regulatory Tailoring Enhancement Act H.R.8287 - Stress Testing Accountability and Transparency Act H.R. 2835, the Small Bank Holding Company Relief Act H.R. 3709, the Advancing the Mentor-Protege Program for Small Financial Institutions Act H.R. 3716, the Systemic Risk Authority Transparency Act H.R. 940, the Fair Audits and Inspections for Regulators' (FAIR) Exams Act H.R. 3379, the Halting Uncertain Methods and Practices in Supervision (HUMPS) Act of 2025 H.R. 3380, the Taking Account of Institutions with Low Operation Risk (TAILOR) Act of 2025 S.2019 - Task Force for Recognizing and Averting Payments Scams (TRAPS) Act H.R. 3390, the Bringing the Discount Window into the 21st Century Act H.R. 4460, the Stop Agency Fiat Enforcement of Guidance (SAFE Guidance) Act H.R. 3446, the FDIC Board Accountability Act H.R. 4544, The American Access to Banking Act H.R. 4478, the Tailored Regulatory Updates for Supervisory Testing Act of 2025 (TRUST Act) H.R. 4437, the Supervisory Modifications for Appropriate Risk-Based Testing Act of 2025 (SMART Act) H.R. 5270, the Stress Testing Accountability and Transparency Act H.R. 5276, the Community Bank Leverage Improvement and Flexibility for Transparency (Community Bank LIFT) Act H.R. 5291, the Merchant Banking Modernization Act H.R. 5262, the Bank Competition Modernization Act Legislation to support Minority Depository Institutions H.R. 6553, the Tailoring and Indexing Enhanced Regulations (TIER) Act H.R. 6554, the Community Bank Representation Act H.R. 6536, Rural Depositories Revitalization Study Act H.R. 6551, the New Bank Application Numbers Knowledge Act (New BANK) Act H.R. 6546, Merger Process Review Act H.R. 6570, the Merger Agreement Approvals Clarity and Predictability Act H.R. 6544, The Regulatory Efficiency, Verification, Itemization, and Enhanced Workflow (REVIEW) Act H.R. 6550, the American Financial Institution Regulatory Sovereignty and Transparency (American FIRST) Act H.R. 6555, the Enhancing Bank Resolution Participation Act Ensuring Fair Access to Banking Act H.R. 6955, the Main Street Capital Access Act H.R. 7056, the Community Bank Regulatory Tailoring Act S.3940, the Access to Fair Financing for Opportunity and Resilient Development (AFFORD) Act S. 3017, the STREAMLINE Act H.R. 1799, the Financial Reporting Threshold Modernization Act

Client expense: $3,140,000 · Firm income: Not reported

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

H.R. 1013/S. 424, Retirement Fairness for Charities and Educational Institutions Act of 2025 H.R. 1109, Litigation Transparency Act of 2025, and potential amendments thereto H.R. 1190/S. 577, Expanding Access to Capital for Rural Job Creators Act H.R. 1799, Financial Reporting Threshold Modernization Act H.R. 2225/S. 1808, Access to Small Business Investor Capital Act H.R. 2441/S. 1877, Improving Disclosure for Investors Act of 2025 H.R. 2675/S. 3180, Protecting Our Courts From Foreign Manipulation Act of 2025 H.R. 3301, ELEVATE Act of 2025 H.R. 3339, Equal Opportunity for All Investors Act of 2025 H.R. 3343, Greenlighting Growth Act of 2025 H.R. 3351, Improving Access to Small Business Information Act H.R. 3352, HALOS Act of 2025 H.R. 3381, Encouraging Public Offerings Act of 2025 H.R. 3382/S. 2924, Small Entity Update Act H.R. 3383/S. 3671, Increasing Investor Opportunities Act H.R. 3394, Fair Investment Opportunities for Professional Experts Act H.R. 3645, ACCESS Act of 2025 H.R. 3673, Small Business Investor Capital Access Act H.R. 3682/S. 3578, Financial Stability Oversight Council Improvement Act of 2025 H.R. 3959, Protecting Private Job Creators Act H.R. 4171, Small Entrepreneurs Empowerment and Development (SEED) Act of 2025 H.R. 4429, Developing and Empowering Our Aspiring Leaders (DEAL) Act H.R. 4430, Expanding WKSI Eligibility Act H.R. 4431, Improving Capital Formation for Newcomers (ICAN) Act H.R. 6955, Main Street Capital Access Act H.R. 7056, Community Bank Regulatory Tailoring Act H.R. 7085, to repeal certain disclosure requirements related to conflict minerals H.R. 7127, Restoring Secondary Market Trading Act H.R. 7128, Terrorism Risk Insurance Act of 2026 S. 985, PROTECT USA Act S. 2934, Protecting Americans from Russian Litigation Act of 2025, and potential litigation funding issues thereunder S. 3826, Litigation Funding Transparency Act of 2026 Potential legislation similar to H.R. 448, Putting Investors First Act Potential legislation similar to H.R. 2590, Unlocking Capital for Small Business Act of 2023 Potential legislation similar to H.R. 2607, Improving Crowdfunding Opportunities Act, 2023 Potential legislation similar to H.R. 2622, to amend the Investment Advisers Act of 1940 to codify certain Securities and Exchange Commission no-action letters that exclude brokers and dealers compensated for certain research services from the definition of investment adviser Potential legislation similar to H.R. 2651, Regulation A+ Improvement Act of 2023 Potential legislation similar to H.R. 2799, the Investment Opportunity Expansion Act, 2023 Potential legislation similar to H.R. 4168/S. 2005, Mandatory Materiality Act Potential legislation similar to H.R. 4767, Protecting Americans Retirement Savings from Politics Act Potential legislation similar to H.R. 6623/S. 2068, Main Street Growth Act Potential legislation similar to S. 5139, Empowering Main Street in America Act (EMSAA) of 2024 Potential legislation to repeal the SECs Universal Proxy Rule of 2021 Potential legislation to amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to repeal certain rulemaking requirements Potential legislation to prevent the premature seizure of an individuals securities, digital assets, or investment accounts in the custody of a financial institution under State escheatment laws, and for other purposes Potential legislation to amend the definition of accredited investor to include individuals receiving advice from certain professionals, and for other purposes SEC Proposed Rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors (87 Fed. Reg. 21,334-21,473, April 11, 2022) Various issues relating to potential housing finance reform legislation; Basel III Endgame Rule; issues related to the Export-Import Bank of the United States; European Unions (EU) Corporate Sustainability Due Diligence Directive (CSDDD); reauthorization of the U.S. International Development Finance Corporation; implementation of the One Big Beautiful Bill Act, (P.L. 119-21); implementation of Disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Overdraft Lending: Very Large Financial Institutions" (P.L. No: 119-10); implementation of A joint resolution disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications" (P.L. No: 119-11); proxy process and shareholder proposal system overseen by SEC; proxy process, proxy advisory firms, and other related aspects of corporate governance; FSOC Nonbank Guidance - request to restore the 2019 Guidance (July 14, 2025, letter to Treasury); reporting metrics of American companies under the EUs Corporate Sustainability Reporting Directive and Corporate Sustainability Due Diligence Directive; index fund passivity; reform to the function of the Public Company Accounting Oversight Board; rulemaking regarding corporate exemptions for shareholder proposals under SEC Rule 14a-8; rulemaking regarding reform to the proxy voting advice industry at the SEC; request for comment from SEC on potential revisions to executive compensation disclosure; request for comment from SEC on potential revisions to definition of Foreign Private Issuer; SEC Compliance and Disclosure Interpretations: Regulation 13D-G (February 11, 2025); potential policy affirming materiality as the standard for corporate disclosure at the SEC; Executive Order 14366, Protecting American Investors from Foreign-Owned and Politically-Motivated Proxy Advisors; Executive Order 14330, Democratizing Access to Alternative Assets for 401(K) Investors; SEC Staff Review ADI 2025-16 on Registered Closed-End Funds of Private Funds (August 15, 2025); acquired fund fees and expenses mandate under Rule 12d1-4 (impact of AFFE on BDCs and inclusion of alternative assets in 401(K)s); potential policy from SEC on electronic delivery of investor disclosure information; capital formation policy to expand access to capital for small businesses, strengthen public markets, and increase opportunities for investors; oversight issues and potential legislation on third party litigation funding, including its national security implications; insurance related litigation; oversight of the federal judiciary regarding third party litigation funding

Client expense: $19,750,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Labor, Dept of (DOL), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Trade Representative (USTR)

Issues pertaining to Banking Access; issues relating to banking in general; Payments Issues; issues pertaining to Deposit Insurance; issues pertaining to Data Privacy; issues pertaining to Bank Capital Standards; Interchange Issues; issues pertaining to BSA/AML; H.R. 1799, Financial Reporting Threshold Modernization Act, all provisions; H.R. 7035/S. 3623, Credit Card Competition Act of 2026, all provisions; issues pertaining to Access to Capital; H.R. 2392, STABLE Act of 2025, all provisions; S. 394, GENIUS Act of 2025, all provisions; H.R. 3633, Digital Asset Market Clarity Act of 2025, all provisions.

Client expense: $720,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Advocated for policies impacting the broader banking system, payments, and financial regulatory framework, including: Bank Secrecy Act (BSA) / CTR Threshold Modernization: Supported legislation to update and index Currency Transaction Report (CTR) thresholds for inflation, including H.R. 1799, the Financial Reporting Threshold Modernization Act. Advocacy focused on reducing outdated regulatory burdens while maintaining effective anti-money laundering (AML) safeguards. Credit Card Interest Rate Caps: Opposed legislative proposals to impose a federal cap on credit card interest rates (e.g., 10 percent cap), citing concerns regarding reduced access to credit for higher-risk borrowers and disruption of risk-based pricing in unsecured lending. Interchange / Credit Card Routing Mandates: Opposed proposals to expand interchange routing requirements to credit cards, including the Credit Card Competition Act. Advocacy emphasized the role of interchange revenue in funding fraud prevention, cybersecurity, and consumer protections, as well as concerns about increased fraud risk and limited pass-through savings to consumers. Durbin Amendment Threshold Indexing: Supported legislative efforts to index the asset threshold for interchange regulation under the Durbin Amendment to inflation to preserve exemptions for smaller financial institutions, including S. 3849, the Community Bank Relief Act. Fraud Prevention and Scam Mitigation (TRAPS Act): Supported legislative efforts to address financial fraud and scams, including H.R. 4936 and S. 2019 (TRAPS Act). Advocacy included promoting interagency coordination, enhanced data-sharing, and tools for financial institutions to detect and prevent fraudulent activity. Consumer Financial Data Access (Section 1033): Engaged on rulemaking under Section 1033 of the Dodd-Frank Act regarding consumer financial data access. Advocacy focused on data security, appropriate liability allocation, and cost recovery for financial institutions providing third-party data access.

Client expense: $70,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), SENATE

Issues related to money transmission services, federal financial regulation, consumer protection, the Bank Secrecy Act (BSA), and remittance consumer identification issues; S.3017, STREAMLINE Act; H.R.1799, Financial Reporting Threshold Modernization Act.

Client expense: Not reported · Firm income: $60,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Preserving credit union tax exemption; Tax Cuts and Jobs Act; HR 654 (move CFPB to appropriations); HJRes 59 (repeal overdraft rule); SJRes 18 (repeal overdraft rule); expansion of CFI definition under the FHLB; S. 522, Credit Union Board Modernization Act; S. 2019, the TRAPS Act (fraud prevention); Small Business Administration lending letter; the GENIUS Act (crypto & stablecoin); H.R. 507, the veterans member business lending act; HR 1799, the Financial Reporting Threshold Modernization Act; HR 4167/S. 3616, Expanding Access to Lending Options Act; S. 2545, the Expanding NCUA Liquidity Facility Enhancements Act; National Defense Authorization Act; Credit Card Competition Act (interchange); affordable housing; budget reconciliation; CU tax exemption; H.R. 7548/S. 3674, the SCAM Act

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

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

H.R. 478 The Promoting New Bank Formation Act H.R. 940 The FAIR Exams Act H.R. 941 The Small LENDER Act H.R. 976 The 1071 Repeal to Protect Small Business Lending Act H.R. 1606 Making the CFPB Accountable to Small Businesses Act H.R. 1652 Rectifying UDAAP Act H.R. 1799 The Financial Reporting Threshold Modernization Act H.R. 1944 10 Percent Credit Card Interest Rate Cap Act H.R. 2808 The Homebuyers Privacy Protection Act H.R. 2835 The Small Bank Holding Company Relief Act H.R. 2885 The Bank Loan Privacy Act H.R. 3234 Reciprocal Deposits H.R. 3380 TAILOR Act of 2025 H.R. 3390 Bringing the Discount Window into the 21st Century Act H.R. 3446 FDIC Board Accountability Act- Rep. Huizenga H.R. 3633 The CLARITY Act H.R. 3709 Advancing the Mentor-Protege Program for Small Financial Institutions Act H.R. 4437 SMART Act H.R. 4478 TRUST Act H.R. 4551 The Employee Paycheck and Small Business Protection Act H.R. 5262 The Bank Competition Modernization Act H.R. 5276 The Community Bank LIFT Act H.R. 5263 The Bank Competition Modernization Act H.R. 5291 The Merchant Banking Modernization Act H.R. 5317 The Community Bank Deposit Access Act of 2025 H.R. 5577 The NFIP Extension Act of 2026 (Rep. Andrew Garbarino) H.R. 6536 The Rural Depositories Revitalization Study Act (Rep. Ralph Norman) H.R. 6544 The Regulatory Efficiency, Verification, Itemization, and Enhanced Workflow (REVIEW) Act (Rep. William Timmons) H.R. 6547 The Least Cost Exception Act H.R. 6552 The Bank-Fintech Partnership Enhancement Act (Rep. Andy Barr) H.R. 6554 The Community Bank Representation Act (Rep. Monica De La Cruz) H.R. 6555 The Enhancing Bank Resolution Participation Act H.R. 6556 The Failing Bank Acquisitions Fairness Act H.R. 6955 Main Street Capital Access Act H.R. 7056 Community Bank Regulatory Tailoring Act H.R. 7548 The SCAM Act H.R. 7769 Municipal Investment and Neighborhood Transformation Act H.R. 8071 Fair Exams Act H.R. 8075 Emergency Transaction Account Guarantee Program H.R. 8087 Main Street Depositor Protection Act H.R. 8088 Growing Deposit Insurance for the Future Act S. 113 The Promoting New Bank Formation Act S. 427 The TAILOR Act S. 557 The 1071 Repeal to Protect Small Business Lending Act S. 1467 Homebuyers Privacy Protection Act S. 2352 The PROTECTED Act S. 2486 Protecting Access to Credit for Small Businesses Act S. 2663 Merchant Banking Modernization Act S. 2704 CDFI Fund Transparency Act S. 2999 Main Street Depositor Protection Act S. 3774 The SCAM Act S. 3830 TRUST Act S. 3941 Municipal Investment and Neighborhood Transformation Act Amendment 3640 to S. 2296 National Defense Authorization Act - CDFIs CFPB 1033 Rule Community Bank Access to Capital Credit Card Competition Act Credit Union Acquisitions of Community Banks Credit Union Field of Membership Rules Data Privacy De Novo Bank Formation Deposit Insurance Digital Assets Regulation EGRPRA Review Federal Reserve Master Accounts Flood Insurance Fraud and Scams Industrial Loan Company Charter Policy Minority Depository Institutions Mutual Bank Capital Certificates National Trust Bank Charter Rules and Applications Regulatory Relief Stablecoin Regulation To authorize the FDIC and NCUA to establish emergency transaction account guarantee programs, and for other purposes To require the FDIC and NCUA to carry out an analysis to determine whether insurance coverage should be raised on covered transaction accounts, and for other purposes The Growing Deposit Insurance for the Future Act

Client expense: $890,000 · Firm income: Not reported

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

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 standard as the financial service industry has to abide by and require that retailers notify credit unions sooner once a breach occurs. We support the introduction and passage of legislation that ensures all businesses, institutions and organizations that collect, collect, use or share personal data 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 the Veterans Member Business Loan Act (S.210/H.R. 507) that would exempt credit union business loans to veterans from the member business lending cap and we are supporting the Credit Union Board Modernization Act (S.522/H.R. 975) which would afford federal credit unions flexibility with regard to how often their boards meet. 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 their 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 urging lawmakers in the House to co-sponsor and support H.R. 1799, the Financial Reporting Threshold Modernization Act which would increase the CTR threshold from $10k to $30k and index it going forward for inflation. It would also increase the SAR threshold from $5k to $10k. 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 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. Lastly, credit unions are non-for-profit member-owned financial institutions. 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.

Client expense: $40,000 · 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 145 million members Support regulatory relief for credit unions Support holistic evaluation of regulatory burden on 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 modifying the credit union member business lending cap Support NCUAs existence as an independent regulator and insurer of credit unions Support assistance for minority depository institution credit unions Support regulatory relief for de novo credit unions Support harmonization of federal cyber incident notification standards Oppose Community Reinvestment Act requirements for credit unions Oppose legislative action to restrict credit union overdraft and courtesy pay programs Support regulatory framework for artificial intelligence that allows responsible innovation and recognizes credit unions compliance with existing regulations Support allowing use of artificial intelligence for regulatory reporting purposes Support mandatory arbitration agreements Oppose national interest rate cap Oppose national credit card interest rate cap Support Federal Credit Union Act modernization Support expanded natural person and corporate credit union investment authority Support expanded credit union examination cycle Support increased examination transparency Support Central Liquidity Facility and Community Development Revolving Loan Fund enhancements Oppose NCUA examination of credit union vendors 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 Oppose additional Call Report fields on loans to credit union officials and senior executive staff Oppose additional Call Report fields on maturity distribution of uninsured shares Oppose making changes to Call Report requirements without using notice-and-comment process Oppose NCUA Call Report collection of overdraft and NSF fee revenue data Support modernization and simplification of Call Report form and instructions Support rescission of NCUA overdraft and NSF fee guidance Oppose collection of vendor information in NCUA Credit Union Profile Oppose changes to NCUA collection forms outside rulemaking process Support NCUA review of normal operating level and methodology Support NCUA action to permit credit union reimbursement of dependent care expenses for federal credit union official duties Oppose NCUA acting as a climate regulator Oppose NCUA rule on succession planning Oppose NCUA rule on record retention Oppose excessive NCUA requirements for supervisory committee audits Support NCUA action to reduce scope of supervisory committee examination 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 action to clarify loan participation limits Support NCUA modification of low-income designation process Support expanding NCUA qualified charity definition Support allowing greater weighted average life for corporate credit unions financial assets Support extension of maturity limit for corporate credit union borrowing Support NCUA adopting limited retention period for operational records Support increased flexibility for advertising and notice of insured status Oppose proposed incentive-based compensation rule Support increased compliance timeline for NCUA simplification of share insurance rule Support removing reputational risk as a component of credit union examinations Support balanced implementation of debanking executive order Support increased NCUA efforts to promote credit union industry Support modernization and streamlining of NCUA operations Support NCUA supervisory flexibility for credit union shutdown assistance efforts Support NCUA action to modernize CAMELS rating system Support modernization of NCUA fidelity bond review requirements Support making CFPB subject to regular appropriations process Support increased CFPB budget transparency Support restructuring CFPB leadership to a bipartisan commission Support creation of a CFPB Inspector General Support reforms to CFPB Civil Investigative Demand process Support increasing asset thresholds for CFPB supervision of credit unions 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 use of cost-benefit analysis in rulemaking process 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 Oppose CFPB efforts to restrict information in credit reports Oppose CFPB efforts to manipulate consumer complaint data Support CFPB engaging in ongoing retrospective review of past regulations Support CFPB consumer complaint database reforms Support CFPB no-action letter program with extended timeline and increased protection of sensitive strategic information Oppose CFPB action to prohibit use of certain contractual terms and conditions Oppose expansion of consumer report and consumer reporting agency definitions under the Fair Credit Reporting Act/Regulation V Support consumer protection regulations for buy-now-pay-later loan providers Support inclusion of buy-now-pay-later loans in FHA underwriting Support CFPB use of Civil Penalty Fund for consumer financial education Support increase of Home Mortgage Disclosure Act reporting thresholds Support removal of disparate impact analysis from Regulation B and modification of discouragement standard Support credit union access to universal service fund letters of credit program Support recognition of unique credit union structure in Financial Data Transparency Act joint data standards Support federal data privacy and security standard that exempts Gramm-Leach-Bliley Act covered institutions, preempts state laws, operates on an opt-out basis, recognizes the complexity of data deletion, and does not authorize private right of action Support increased transparency for fintech bank charter applications Support Treasury development of model forms and qualified vehicle list for auto loan interest deduction Support safe harbor for credit unions related to the auto loan interest deduction Support clarification of remittance transfer tax exemptions Support inclusion of credit unions in Trump Accounts program Oppose development of a central bank digital currency Support credit union access to Federal Reserve liquidity options Support gradual expansion of Fedwire and National Settlement Service operating hours with optional participation Oppose addition of fourth same-day ACH window Support expanded flexibility for accessing the Fed discount window and intraday credit Oppose expanded eligibility for Federal Reserve master account access Oppose Regulation II debit interchange fee cap Oppose Federal Reserve proposed rule on modifying Regulation II debit interchange cap Support improvements to the Federal Reserves Debit Card Issuer Survey Oppose legislative action to impose caps or restrictions on debit or credit interchange fees Oppose legislative action to prohibit the Federal Reserve from paying interest on reserves Support Federal Reserve action to coordinate regulatory guidance on penny circulation issues and management of penny supply Support continued offering of Federal Reserve check services 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 Support clarification of funds definition under Electronic Fund Transfer Act/Regulation E Support clarification of Electronic Fund Transfer Act/Regulation E treatment of digital assets Support increased flexibility for check holds and funds availability requirements Support transition to electronic payments for government payments Support consumer education on transition to electronic payments Support clarification of information sharing safe harbor for identifying and preventing payments fraud Support greater flexibility for credit unions to decline services with clear indica of fraud or elder abuse 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 Treasury and NCUA action to implement regulatory framework for stablecoin issuance Support parity for credit unions related to stablecoin regulation Support NCUAs role as primary regulator of credit unions stablecoin activities Oppose treating stablecoins or digital assets as federally insured Oppose payment of interest, yield, or rewards on stablecoin holdings Support digital assets guardrails to prevent deposit outflows Support clarifying credit unions authority to provide custodial services for their members Support safeguards for rehypothecation of digital assets Support reduced government-sponsored enterprises costs for credit union mortgages Support secondary mortgage market access for credit unions Support continued role for FHFA as an independent regulator Support credit union access to Federal Home Loan Bank system 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 Federal Home Loan Bank allocations to the Affordable Housing Program Support FinCEN implementation of the Corporate Transparency Act Support additional time to implement anti-money laundering/countering financing of terrorism program changes and publication of guidance Support increasing Currency Transaction Report and Suspicious Activity Report filing thresholds Support streamlining Currency Transaction Report and Suspicious Activity Report forms Support increased inclusion of identifiable information in Section 314(a) information requests Support consistency between NCUA and FinCEN requirements on Bank Secrecy Act compliance Support FinCEN survey to accurately measure Bank Secrecy Act compliance costs Support DOD clarification of Military Lending Act and Servicemembers Civil Relief Act requirements Support standardized disclosures and financial literacy briefings for servicemembers Support credit union access to nominal leases on military installations Oppose nominal leases for banks on military installations Oppose legislative action on the Overseas Military Banking Program Oppose inclusion of interchange or interest rate cap amendments in the National Defense Authorization Act Support federal share insurance for all credit unions acting as fiscal agents of the U.S. government Support role of Community Development Financial Institutions Fund in promoting economic growth and access to capital in underserved communities Support access to Community Development Financial Institutions Fund awards and technical assistance for credit unions Support Community Development Financial Institutions Fund bond guarantee program Support Community Development Financial Institutions Fund liquidity enhancement pilot program Support disbursement of all Community Development Financial Institution Fund appropriated award funding Oppose additional barriers to disbursement of Community Development Financial Institution Fund appropriated award funding Support timely completion of Emergency Capital Investment Program disposition agreements Oppose CFPB rulemaking on contract terms and conditions Oppose reclassification of credit header information as a consumer report Oppose reliance on single source of documentation to determine instances of identity theft or coerced debt Oppose use of interim final rule to modify personal financial data rights requirements Support modification of Section 1033 rule to allow data providers to charge fees, remove prescriptive technology standards, and establish data privacy standards and allocation of liability Support increased reporting and small business revenue threshold and elimination of discretionary data points collection in revised Section 1071 rule Support modernization of e-signature requirements Support allowing electronic or documented oral credit card applications Support increased flexibility for disclosures Support rescission of CFPB payday lending rule payment provisions Support modification of FCC revocation of consent rule Support greater flexibility for FCC fraud alert exemption Support uniform federal standards and increased federal preemption of state laws on interchange, data privacy, artificial intelligence, and elder financial abuse reporting 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 Credit Union Board Modernization Act (H.R. 975; S. 522) Support 1071 Repeal to Protect Small Business Lending Act (H.R. 976; S. 557) Support Making the CFPB Accountable to Small Businesses Act (H.R. 1606) Support Financial Integrity and Regulation Management Act (S. 875; H.R. 2702; Senate Amendment 3104) Support Fair Audits and Inspections for Regulators Act (H.R. 940) Support Anti-CBDC Surveillance State Act (H.R. 1919; S. 1124) Support Veterans Member Business Loan Act (H.R. 507; S. 110; Senate Amendment 3776) Support Taking Account of Bureaucrats Spending Act (H.R. 654) Support Rectifying UDAAP Act (H.R. 1652) Support Civil Investigative Demand Reform Act (H.R. 1653) Support SECURE Notarization Act (H.R. 1777; S. 1561) Support Increasing Credit Union Lending for Business Growth Act (H.R. 1791) Support Financial Reporting Threshold Modernization Act (H.R. 1799; Amendment 715 to H.R. 3838) Support Home of Your Own Act (H.R. 2064) Support Homes for Every Local Protector, Educator, and Responder Act (H.R. 2094; S. 978) Support CFPB Dual Mandate and Economic Analysis Act (H.R. 2183) Support Transparency in CFPB Cost-Benefit Analysis Act (H.R. 2331) Support CFPB-IG Reform Act (H.R. 2513) Support Homebuyers Privacy Protection Act (H.R. 2808; S. 1467) Support Financial Institution Regulatory Tailoring Enhancement Act (H.R. 3230) Support Halting Uncertain Methods and Practices in Supervision Act (H.R. 3379) Support Taking Account of Institutions with Low Operation Risk Act (H.R. 3380) Support Bureau of Consumer Financial Protection Commission Act (H.R. 3445) Support Advancing the Mentor-Protege Program for Small Financial Institutions Act (H.R. 3709) Support Expanding Access to Lending Options Act (H.R. 4167) Support CDFI Bond Guarantee Program Improvement Act (S. 1880) Support Taskforce for Recognizing and Averting Payment Scams Act (H.R. 4936; S. 2019; Senate Amendment 3257) Support Capping Excessive Awarding of SBLC Entrants Act (H.R. 2987) Support Expanding Access to Lending Options Act (H.R. 4167) Support Supervisory Modifications for Appropriate Risk-Based Testing Act (H.R. 4437) Support Stop Agency Fiat Enforcement Act (H.R. 4460) Support American Access to Banking Act (H.R. 4544) Support Protecting Access to Credit for Small Businesses Act (S. 2486) Support Business of Insurance Regulatory Reform Act (H.R. 4735; S. 2419) Support NCUA Central Liquidity Facility Enhancement Act (S. 2545, S. 3575; Senate Amendments 3722, 3834, 4384) Support CDFI Fund Transparency Act (S. 2704; Senate Amendments 3640, 3732) Support Supporting Upgraded Property Projects and Lending for Yards Act (H.R. 4568) Support Unleashing AI Innovation in Financial Services Act (H.R. 4801) Support AI Practices, Logistics, Actions, and Necessities Act (H.R. 2152) Support Streamlining Transaction Reporting and Ensuring Anti-Money Laundering Improvements for a New Era Act (S. 3017) Support NFIP Continuation Act (H.R. 5577) Support Housing for the 21st Century Act (H.R. 6644) Support Regulatory Efficiency, Verification, Itemization, and Enhanced Workflow Act (H.R. 6544) Support Community Bank Regulatory Tailoring Act (H.R. 7056) Support Close the Shadow Banking Loophole Act (S. 3734) Support American Lending Fairness Act (S. 3889; H.R. 7866) Support Community Bank Relief Act (S. 3849; H.R. 7484) Support Access to Fair Financing for Opportunity and Resilient Development Act (Senate Amendments 4354, 4394; S. 3940) Support Growing Deposit Insurance for the Future Act (H.R. 8088) Support emergency transaction account guarantee legislation (H.R. 8075) Support inclusion of guidance on penny circulation in Common Cents Act (H.R. 3074) Support parity for credit unions and prohibition on stablecoin yield in Digital Asset Market Clarity Act (H.R. 3633) Support modification of Section 705 in Renewing Opportunity in the American Dream to Housing Act (S. 2651) Support inclusion of credit union parity provisions in Main Street Capital Access Act (H.R. 6955) Oppose 10 Percent Credit Card Interest Rate Cap Act (H.R. 1944; S. 381; Senate Amendment 2239) Oppose Credit Card Competition Act (Senate Amendments 2229, 2230, 2345, 4305; S. 3623; H.R. 7035) Oppose commissary interchange fee study (Senate Amendment 3216) Oppose End the Feds Big Bank Bailout Act (S. 2113; Senate Amendment 3761) Oppose Credit Card Fairness Act (S. 3660)

Client expense: $1,130,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Executive Office of the President (EOP), 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), Justice, Dept of (DOJ), Natl Credit Union Administration (NCUA), Natl Economic Council (NEC), Office of Management & Budget (OMB), SENATE, Small Business Administration (SBA), Treasury, Dept of

Issues related to money transfer services, de-risking and fintech; Issues related to consumer protection standards; Issues related to Dodd-Frank; Issues related to federal financial regulation; Issues related to digital assets; Issues related to improving scam prevention and fraud protection standards; H.R. 1799, Financial Reporting Threshold Modernization Act

Client expense: $90,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. 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 develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Appropriate Regulation of Fintechs and Innovations in Financial Services The pace of innovation in financial services has been accelerating. Many of these new services are offered by financial technology companies - better known as fintechs. Financial innovation presents community banks with challenges and opportunities. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose unreasonable requirements on them, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Prescriptive and Intrusive FDIC Corporate Governance Guidelines In 2023, the FDIC proposed new corporate governance and risk management guidelines. Although the guidelines only apply to covered institutions with $10 billion or more in assets, these overly prescriptive guidelines apply the same set of standards to larger community banks as they do to the nations largest banks. These guidelines would make it even more difficult to attract new directors, particularly those in rural areas. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach 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. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. 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, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. De Novo Community Bank Formation, the Dual Banking System, and Charter Choice The chartering of many newly chartered (de novo) community banks is vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of continued banking industry consolidation. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, where chartering and supervision are divided between the federal government and the states, and where the federal government supervision and regulation is divided between the Federal Reserve, Office of Comptroller of the Currency, and the Federal Deposit Insurance Corporation. Community banks should be able to choose the banking charter and associated prudential regulator that best fits their unique needs and business model. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. Responsible Bank Merger Activity Some community banks have found it helpful to merge with other community banks to be able to spread the significant and escalating costs of regulatory compliance, cybersecurity, technology and innovation to remain highly competitive. Restrictive bank merger legislation or regulations should not apply to community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Insure) Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts Too-Big-To-Not-Insure The 2023 failures of Silicon Valley Bank and Signature Bank revealed that policymakers have created a new category of very large banks - Too-Big-To-Not-Insure (although they will fail) because the FDIC decided to insure 100% of the uninsured deposits of these two failed banks. There must be accountability by both the banks and the regulators for their respective failures. In the future, if systemically important financial institutions (SIFIs) cause losses to the DIF then SIFIs should be responsible for reimbursing the DIF for all the losses they created. Too-Big-To-Fail The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 1799 the Threshold Modernization Act (All Sections) regarding thresholds for currency transaction reporting and Suspicious Activity Reporting (SAR) (House) H.R. 7056 the Community Bank Tailoring Act (All Sections) regarding indexing various asset-based and bank-regulatory reporting thresholds o nominal GDP for community banks (House) H.R. 6955 the Main Street Capital Access Act (All Sections) regarding regulatory fairness, transparency and right-sizing; promoting healthy, growing, and competitive banking industry; and improving access o funding and capital for small to mid-sized banks (House) H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding he inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House and Senate) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the FDIC regarding PayPal Holdings, Inc. application to the FDIC for deposit insurance for PayPal Bank (FDIC) Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the OCC, FDIC and Federal Reserve regarding Notice of Proposed Rulemaking: Regulatory Capital Rule: Revisions to the Community Bank Leverage Ratio Framework - Docket ID OCC-2025-0141, Federal Reserve Docket No. R-1876 and RIN 7100-AH08, and FDIC RIN 3064-AG17 (OCC, FDIC and Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comment on Reserve Board Payment Account Prototype - Docket No. OP-1877 (aka Fed skinny payment accounts) (Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Comment Letter to the OCC regarding Notice of Proposed Rulemaking: Revised Guidelines - OCC Guidelines Establishing Heightened Standards for Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches; Technical Amendments - Docket ID OCC-2025-0207 (OCC) Action Alerts - Action Alert - Urge Your Representative to Support Community Bank Regulatory Relief (House) (See H.R. 6644 Housing for the 21st Century Act above) Miscellaneous - Potential House field hearing on financial fraud (House) Approval of application for Kraken master account with the Federal Reserve (House) EGRPRA Outreach Meeting presentation on March 26, 2026, regarding de novos, particularly newly chartered community banks (OCC, FDIC, Federal Reserve)

Client expense: $65,000 · Firm income: Not reported

Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of the Comptroller of the Currency (OCC), SENATE

CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. 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 develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Appropriate Regulation of Fintechs and Innovations in Financial Services The pace of innovation in financial services has been accelerating. Many of these new services are offered by financial technology companies - better known as fintechs. Financial innovation presents community banks with challenges and opportunities. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose unreasonable requirements on them, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Prescriptive and Intrusive FDIC Corporate Governance Guidelines In 2023, the FDIC proposed new corporate governance and risk management guidelines. Although the guidelines only apply to covered institutions with $10 billion or more in assets, these overly prescriptive guidelines apply the same set of standards to larger community banks as they do to the nations largest banks. These guidelines would make it even more difficult to attract new directors, particularly those in rural areas. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach 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. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. 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, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. De Novo Community Bank Formation, the Dual Banking System, and Charter Choice The chartering of many newly chartered (de novo) community banks is vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of continued banking industry consolidation. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, where chartering and supervision are divided between the federal government and the states, and where the federal government supervision and regulation is divided between the Federal Reserve, Office of Comptroller of the Currency, and the Federal Deposit Insurance Corporation. Community banks should be able to choose the banking charter and associated prudential regulator that best fits their unique needs and business model. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. Responsible Bank Merger Activity Some community banks have found it helpful to merge with other community banks to be able to spread the significant and escalating costs of regulatory compliance, cybersecurity, technology and innovation to remain highly competitive. Restrictive bank merger legislation or regulations should not apply to community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Insure) Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts Too-Big-To-Not-Insure The 2023 failures of Silicon Valley Bank and Signature Bank revealed that policymakers have created a new category of very large banks - Too-Big-To-Not-Insure (although they will fail) because the FDIC decided to insure 100% of the uninsured deposits of these two failed banks. There must be accountability by both the banks and the regulators for their respective failures. In the future, if systemically important financial institutions (SIFIs) cause losses to the DIF then SIFIs should be responsible for reimbursing the DIF for all the losses they created. Too-Big-To-Fail The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 1799 the Threshold Modernization Act (All Sections) regarding thresholds for currency transaction reporting and Suspicious Activity Reporting (SAR) (House) H.R. 7056 the Community Bank Tailoring Act (All Sections) regarding indexing various asset-based and bank-regulatory reporting thresholds o nominal GDP for community banks (House) H.R. 6955 the Main Street Capital Access Act (All Sections) regarding regulatory fairness, transparency and right-sizing; promoting healthy, growing, and competitive banking industry; and improving access o funding and capital for small to mid-sized banks (House) H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding he inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House and Senate) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the FDIC regarding PayPal Holdings, Inc. application to the FDIC for deposit insurance for PayPal Bank (FDIC) Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the OCC, FDIC and Federal Reserve regarding Notice of Proposed Rulemaking: Regulatory Capital Rule: Revisions to the Community Bank Leverage Ratio Framework - Docket ID OCC-2025-0141, Federal Reserve Docket No. R-1876 and RIN 7100-AH08, and FDIC RIN 3064-AG17 (OCC, FDIC and Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comment on Reserve Board Payment Account Prototype - Docket No. OP-1877 (aka Fed skinny payment accounts) (Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Comment Letter to the OCC regarding Notice of Proposed Rulemaking: Revised Guidelines - OCC Guidelines Establishing Heightened Standards for Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches; Technical Amendments - Docket ID OCC-2025-0207 (OCC) Action Alerts - Action Alert - Urge Your Representative to Support Community Bank Regulatory Relief (House) (See H.R. 6644 Housing for the 21st Century Act above) Miscellaneous - Potential House field hearing on financial fraud (House) Approval of application for Kraken master account with the Federal Reserve (House) EGRPRA Outreach Meeting presentation on March 26, 2026, regarding de novos, particularly newly chartered community banks (OCC, FDIC, Federal Reserve)

Client expense: $65,000 · Firm income: Not reported

Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of the Comptroller of the Currency (OCC), SENATE

Lobbying to protect the credit union federal income tax exemption amid efforts to extend the 2017 Tax Cuts and Jobs Act (H.R. 1 [One Big Beautiful Bill]), advance regulatory relief through efforts to modernize the Currency Transaction Report filing threshold (H.R. 1799 [Financial Reporting Threshold Modernization Act), increase the threshold for small business lending exemption from $50,000 to $100,000, preserve the CDFI Fund and maintain funding levels, increase education and support for combatting fraud through the Taskforce for Recognizing and Averting Payment Scams Act (S. 2019).

Client expense: $70,000 · Firm income: Not reported

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

Lobbying to protect the credit union federal income tax exemption amid efforts to extend the 2017 Tax Cuts and Jobs Act (H.R. 1 [One Big Beautiful Bill]), advance regulatory relief through efforts to modernize the Currency Transaction Report filing threshold (H.R. 1799 [Financial Reporting Threshold Modernization Act), increase the threshold for small business lending exemption from $50,000 to $100,000, preserve the CDFI Fund and maintain funding levels, increase education and support for combatting fraud through the Taskforce for Recognizing and Averting Payment Scams Act (S. 2019).

Client expense: $70,000 · Firm income: Not reported

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

H.R. 478 The Promoting New Bank Formation Act H.R. 940 The FAIR Exams Act H.R. 941 The Small LENDER Act H.R. 976 The 1071 Repeal to Protect Small Business Lending Act H.R. 1606 Making the CFPB Accountable to Small Businesses Act H.R. 1652 Rectifying UDAAP Act H.R. 1799 The Financial Reporting Threshold Modernization Act H.R. 1944 10 Percent Credit Card Interest Rate Cap Act H.R. 2808 The Homebuyers Privacy Protection Act H.R. 2835 The Small Bank Holding Company Relief Act H.R. 2885 The Bank Loan Privacy Act H.R. 3234 Reciprocal Deposits H.R. 3380 TAILOR Act of 2025 H.R. 3390 Bringing the Discount Window into the 21st Century Act H.R. 3446 FDIC Board Accountability Act- Rep. Huizenga H.R. 3633 The CLARITY Act H.R. 3709 Advancing the Mentor-Protege Program for Small Financial Institutions Act H.R. 4437 SMART Act H.R. 4478 TRUST Act H.R. 4551, the Employee Paycheck and Small Business Protection Act H.R. 5262 The Bank Competition Modernization Act H.R. 5276 The Community Bank LIFT Act H.R. 5263 The Bank Competition Modernization Act H.R. 5291 The Merchant Banking Modernization Act H.R. 5317 The Community Bank Deposit Access Act of 2025 H.R. 5577, the NFIP Extension Act of 2026 (Rep. Andrew Garbarino) H.R. 6536, the Rural Depositories Revitalization Study Act (Rep. Ralph Norman) H.R. 6544, the Regulatory Efficiency, Verification, Itemization, and Enhanced Workflow (REVIEW) Act (Rep. William Timmons) H.R. 6547, the Least Cost Exception Act H.R. 6552, the Bank-Fintech Partnership Enhancement Act (Rep. Andy Barr) H.R. 6554, the Community Bank Representation Act (Rep. Monica De La Cruz) H.R. 6555, the Enhancing Bank Resolution Participation Act HR 6556, the Failing Bank Acquisitions Fairness Act H.R. 8071 Fair Exams Act S. 113 The Promoting New Bank Formation Act S. 427 The TAILOR Act S. 557 The 1071 Repeal to Protect Small Business Lending Act S. 1467 Homebuyers Privacy Protection Act S. 2296 National Defense Authorization Act S. 2352 The PROTECTED Act S. 2486 Protecting Access to Credit for Small Businesses Act S. 2663 Merchant Banking Modernization Act S. 2704 CDFI Fund Transparency Act S. 2999 Main Street Depositor Protection Act Amendment 3640 to S. 2296 National Defense Authorization Act - CDFIs Artificial Intelligence Artificial Intelligence Action Plan Bank Loan Privacy Act CFPB 1033 Rule Community Bank Access to Capital Credit Reporting Credit Union Acquisitions of Community Banks Credit Union Field of Membership Rules Cyber Action Plan Cybersecurity Information Sharing Act (CISA) Reauthorization Data Privacy De Novo Bank Formation Deposit Insurance Digital Assets Regulation EGRPRA Review Federal Reserve Master Accounts Flood Insurance Fraud and Scams Industrial Loan Company Charter Policy Issues related to the Federal Home Loan Bank Act Minority Depository Institutions Mutual Bank Capital Certificates Regulatory Relief Responsible Financial Innovation Act Stablecoin Regulation To authorize the FDIC and NCUA to establish emergency transaction account guarantee programs, and for other purposes To require the FDIC and NCUA to carry out an analysis to determine whether insurance coverage should be raised on covered transaction accounts, and for other purposes The Growing Deposit Insurance for the Future Act U.S. National Cybersecurity Strategy U.S. National Security Strategy

Client expense: $1,281,850 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Executive Office of the President (EOP), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Office of Science & Technology Policy (OSTP), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, White House Office

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 standard as the financial service industry has to abide by and require that retailers notify credit unions sooner once a breach occurs. We support the introduction and passage of legislation that ensures all businesses, institutions and organizations that collect, collect, use or share personal data 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 the Veterans Member Business Loan Act (S.210/H.R. 507) that would exempt credit union business loans to veterans from the member business lending cap and we are supporting the Credit Union Board Modernization Act (S.522/H.R. 975) which would afford federal credit unions flexibility with regard to how often their boards meet. 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 their 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 urging lawmakers in the House to co-sponsor and support H.R. 1799, the Financial Reporting Threshold Modernization Act which would increase the CTR threshold from $10k to $30k and index it going forward for inflation. It would also increase the SAR threshold from $5k to $10k. 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 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. Lastly, credit unions are non-for-profit member-owned financial institutions. 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.

Client expense: $60,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Preserving credit union tax exemption; Tax Cuts and Jobs Act; HR 654 (move CFPB to appropriations); HJRes 59 (repeal overdraft rule); SJRes 18 (repeal overdraft rule); expansion of CFI definition under the FHLB; S. 522, Credit Union Board Modernization Act; S. 2019, the TRAPS Act (fraud prevention); Small Business Administration lending letter; the GENIUS Act (crypto & stablecoin); H.R. 507, the veterans member business lending act; HR 1799, the Financial Reporting Threshold Modernization Act; HR 4167, Expanding Access to Lending Options Act; S. 2545, the Expanding NCUA Liquidity Facility Enhancements Act; National Defense Authorization Act; Credit Card Competition Act (interchange); affordable housing

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

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

Issues related to banking and credit unions; issues related to cannabis banking; issues related to deposit insurance; issues related to interchange; issues related to payment networks; issues related to consumer protection rules and regulations; issues related to rules and legislation affecting credit unions; issues related to lending programs and credit union operational flexibility; issues related to community development financial institutions; S. 303; S. 394; S. 401; S. 522; S. 919; S. 940; S. 1582; S. 1880; S. 2019; S. 2296; H.R. 654; H.R. 814; H.R. 975; H.R. 987; H.R. 1603; H.R. 1652; H.R 1791; H.R. 1799; H.R. 2392; H.R. 3633; H.R. 4167; S.J. Res. 18; H.J. Res. 50; H.J. Res. 59.

Client expense: $40,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to banking and credit unions; issues related to cannabis banking; issues related to deposit insurance; issues related to interchange; issues related to payment networks; issues related to consumer protection rules and regulations; issues related to rules and legislation affecting credit unions; issues related to lending programs and credit union operational flexibility; issues related to community development financial institutions; S. 303; S. 394; S. 401; S. 522; S. 919; S. 940; S. 1582; S. 1880; S. 2019; S. 2296; H.R. 654; H.R. 814; H.R. 975; H.R. 987; H.R. 1603; H.R. 1652; H.R 1791; H.R. 1799; H.R. 2392; H.R. 3633; H.R. 4167; S.J. Res. 18; H.J. Res. 50; H.J. Res. 59.

Client expense: $40,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues pertaining to Banking Access; issues relating to banking in general; Payments Issues; issues pertaining to Deposit Insurance; issues pertaining to Data Privacy; issues pertaining to Bank Capital Standards; Interchange Issues; issues pertaining to BSA/AML; H.R. 1799, Financial Reporting Threshold Modernization Act, all provisions; Credit Card Competition Act (no bill number yet), all provisions; issues pertaining to Access to Capital; H.R. 2392, STABLE Act of 2025, all provisions; S. 394, GENIUS Act of 2025, all provisions; H.R. 3633 - Digital Asset Market Clarity Act of 2025, all provisions.

Client expense: $670,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to money transmission services, federal financial regulation, consumer protection, the Bank Secrecy Act (BSA), and remittance consumer identification issues; S.3017, STREAMLINE Act; H.R.1799, Financial Reporting Threshold Modernization Act.

Client expense: Not reported · Firm income: $60,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to money transfer services, de-risking and fintech; Issues related to consumer protection standards; Issues related to Dodd-Frank; Issues related to federal financial regulation; Issues related to digital assets; Issues related to improving scam prevention and fraud protection standards; H.R. 1799, Financial Reporting Threshold Modernization Act

Client expense: $90,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE