Transparency in CFPB Cost-Benefit Analysis Act

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

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)

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) Credit Card Competition Act 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 Dodd-Frank Section 1033 Open Banking Rule Deposit Insurance Reform 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.1631, Safe Access to Cash Act of 2025 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

Protect the credit union tax exemption Support legislation and regulation that advance credit unions and their over 144 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 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 childcare expenses for federal credit union board meetings 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 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 action to reduce scope of supervisory committee examination 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 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 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 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 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; Senate Amendment 3722) 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 inclusion of guidance on penny circulation in Common Cents Act (H.R. 3074) Support parity for credit unions 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) 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) Oppose commissary interchange fee study (Senate Amendment 3216) Oppose End the Feds Big Bank Bailout Act (S. 2113; Senate Amendment 3761)

H.R.736 - To amend title 31, United States Code, to modify the deadline for filing beneficial ownership information reports for reporting companies formed or registered before January 1, 2024. H.R.807 - To direct the Secretary of the Treasury to submit a report on coordination in the public and private sectors in responding to ransomware attacks on financial institutions, and for other purposes. H.R.2331 - To enhance rulemaking requirements for the Bureau of Consumer Financial Protection, and for other purposes. H.R.2531 - To require Senate confirmation of Inspector General of the Bureau of Consumer Financial Protection, and for other purposes. H.R.3230 - To increase the asset thresholds at which financial institutions become subject to certain requirements, and for other purposes. H.R.3289 - To establish a commission on fiscal responsibility and reform. H.R.3484 - To terminate unused authorities of the Securities and Exchange Commission that were established pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act.

Client expense: $442,147 · Firm income: Not reported

H.R. 478/S. 113, Promoting New Bank Formation Act S. 875/H.R. 2702, Financial Integrity and Regulation Management (FIRM) Act S.J. Res. 36/H.J. Res. 74, the resolution to disapproval of the Consumer Financial Protection Bureaus (CFPB) rule prohibiting medical debt information from being reported or used by creditors S.J. Res. 18/H.J. Res. 59, the resolution of disapproval of the final rule issued by the Consumer Financial Protection Bureau (CFPB) on December 12, 2024, regarding overdraft protection services 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) Credit Card Competition Act 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 Dodd-Frank Section 1033 Open Banking Rule CFPB Credit Card Late Fee Rule Deposit Insurance Reform 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 Emergency Capital Investment Issues for CDFI and MDI Institutions UDAAP Supervisory Policies and Adjudication Procedures Community Reinvestment Act Final Rule 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.1631, Safe Access to Cash Act of 2025 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 Notice of Proposed Rulemaking for Debit Card Interchange Fees and Routing (Reg II) Federal Reserve Discount Window and Emergency Lending Authority Tokenization of Assets Fraud Issues Regulatory Tailoring Peer-To-Peer Payment Fraud Financial Data Transparency Act Rulemaking FDIC Brokered Deposit Proposal S. 1467/H.R. 2808 Homebuyers Privacy Protection Act S.J.Res.13, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency of the Department of the Treasury relating to the review of applications under the Bank Merger Act H.J.Res.92 - Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency of the Department of the Treasury relating to the review of applications under the Bank Merger Act. 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.3390 - Bringing the Discount Window into the 21st Century 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

Protect the credit union tax exemption Support legislation and regulation that advance credit unions and their over 144 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 Support regulatory framework for artificial intelligence that allows responsible innovation and recognizes compliance with existing regulations Support allowing use of artificial intelligence for regulatory reporting purposes Support mandatory arbitration agreements Oppose national 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 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 childcare expenses for federal credit union board meetings 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 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 action to reduce scope of supervisory committee examination 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 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 Support exemptions for CFPB Section 1071 final rule Oppose CFPB efforts to restrict information in credit reports Oppose CFPB Section 1071 final rule Oppose prohibition on use of medical debt information in credit decisions 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 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 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 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 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 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 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 consistency between NCUA and FinCEN requirements on Bank Secrecy Act compliance 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 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 Support enhanced transparency and consumer control of financial data 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 Guiding and Establishing National Innovation for U.S. Stablecoins Act (S. 394, S. 919, S. 1582) Support Stablecoin Transparency and Accountability for a Better Ledger Economy Act (H.R. 2392) 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 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 Renewing Opportunity in the American Dream to Housing Act (S. 2651) Support NCUA Central Liquidity Facility Enhancement Act (S. 2545; Senate Amendment 3722) Support CDFI Fund Transparency Act (S. 2704; Senate Amendments 3640, 3732) Support parity for credit unions in Digital Asset Market Clarity Act (H.R. 3633) Support changes to CFPB funding, creation of investment accounts for children, and auto loan interest deduction in H.R. 1 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) Oppose commissary interchange fee study (Senate Amendment 3216)

H.R.736 - To amend title 31, United States Code, to modify the deadline for filing beneficial ownership information reports for reporting companies formed or registered before January 1, 2024. H.R.807 - To direct the Secretary of the Treasury to submit a report on coordination in the public and private sectors in responding to ransomware attacks on financial institutions, and for other purposes. H.R.2331 - To enhance rulemaking requirements for the Bureau of Consumer Financial Protection, and for other purposes. H.R.2531 - To require Senate confirmation of Inspector General of the Bureau of Consumer Financial Protection, and for other purposes. H.R.3230 - To increase the asset thresholds at which financial institutions become subject to certain requirements, and for other purposes. H.R.3289 - To establish a commission on fiscal responsibility and reform. H.R.3484 - To terminate unused authorities of the Securities and Exchange Commission that were established pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act.

Client expense: $435,663 · Firm income: Not reported

CFPB authority and functions, related to structure and supervision, research and enforcement priorities; Supervision and enforcement of unregulated "fintech" products and non-brank lenders; Treatment of medical debt on credit reports; Closure of CFPB Office of Servicemember Affairs, including opposition to the suspension of Military Lending Act enforcement; Ongoing concerns with other office closures and RIFs at CFPB; Ongoing concerns with administration efforts to eliminate or consolidate prudential regulators of banking services; Ongoing concerns with illegal termination of Democratic commissioners at various independent agencies, such as FTC and NCUA; S.J. Res 18 & H.J.Res 59, opposing joint resolutions disapproving the rule submitted by CFPB relating to "Overdraft Lending: Very Large Financial Institutions;" H.R. 654, opposing the Taking Account of Bureaucrats Spending (TABS) Act of 2025; H.R. 976, opposing the 1071 Repeal to Protect Small Business Lending Act; S. 81 / H.R. ____, opposing the Guidance Clarity Act of 2025; S. 875 / H.R. 2702, opposing the Financial Integrity and Regulation Management Act (FIRM Act); S.1582, opposing the GENIUS Act - a bill establishing a regulatory framework for payment stablecoins; S. 1645, opposing the Credit Access and Inclusion Act; H.R. 1606, opposing the Making the CFPB Accountable to Small Businesses Act of 2025; H.R. 1652, opposing the Rectifying UDAAP Act; H.R. 1653, opposing the Civil Investigative Demand Reform Act of 2025; H.R. 2183, opposing the CFPB Dual Mandate and Economic Analysis Act; H.R. 2331, opposing the Transparency in CFPB Cost-Benefit Analysis Act; H.R. 2392, opposing the Stablecoin Transparency and Accountability for a Better Ledger Economy (STABLE) Act of 2025; H.R. 2478, opposing the Financial Exploitation Prevention Act of 2025 H.R. 2513, opposing the CFPB-IG Reform Act of 2025; H.R. 3445, opposing the Consumer Financial Protection Commission Act; H.R. 3446, opposing the FDIC Board Accountability Act; H.R. 3141, opposing the CFPB Budget Integrity Act; H.R. 3633, opposing the Digital Asset Market Clarity Act (CLARITY Act) of 2025; H.R. 4544, supporting the American Access to Banking Act, a bill to promote the formation of de novo regulated institutions; H.R. ____, urging improvements to the Tailored Regulatory Updates for Supervisory Testing Act of 2025 (TRUST Act of 2025); H.R. ____, urging improvements to the Supervisory Modifications for Appropriate Risk-based Testing Act of 2025 (SMART Act of 2025); H.R. ____, opposing a bill to amend the Consumer Financial Protection Act of 2010 to require the attestation of certain information as part of the consumer complaint submission process, and for other purposes; H.R. ____, opposing a bill to amend the Consumer Financial Protection Act of 2010 to provide procedures for guidance issued by the Bureau of Consumer Financial Protection, and for other purposes; H.R. ____, opposing a bill to amend the Consumer Financial Protection Act of 2010 to direct civil penalties to victims and transfer excess funds to the Treasury, and for other purposes; H.R. ____, opposing a bill to amend the Consumer Financial Protection Act of 2010 to eliminate the market monitoring functions of the Bureau of Consumer Financial Protection, and for other purposes; H.R. ____, opposing a bill to amend the Consumer Financial Protection Act of 2010 to revise the structure and maximum amounts of civil monetary penalties, and to provide incentives for the self-reporting of violations; H.R. ____, opposing a bill to amend the Fair Credit Reporting Act to require resellers of information contained in consumer reports to follow reasonable procedures to assure maximum possible accuracy of such information before transmitting such information, and for other purposes; H.R. ____, opposing a bill to amend the civil liability requirements under the Fair Credit Reporting Act to include requirements relating to class actions, and for other purposes;

H.R. 478/S. 113, Promoting New Bank Formation Act S. 875/H.R. 2702, Financial Integrity and Regulation Management (FIRM) Act S.J. Res. 36/H.J. Res. 74, the resolution to disapproval of the Consumer Financial Protection Bureaus (CFPB) rule prohibiting medical debt information from being reported or used by creditors S.J. Res. 18/H.J. Res. 59, the resolution of disapproval of the final rule issued by the Consumer Financial Protection Bureau (CFPB) on December 12, 2024, regarding overdraft protection services 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) Credit Card Competition Act 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 Dodd-Frank Section 1033 Open Banking Rule CFPB Credit Card Late Fee Rule Deposit Insurance Reform 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 Emergency Capital Investment Issues for CDFI and MDI Institutions UDAAP Supervisory Policies and Adjudication Procedures Community Reinvestment Act Final Rule 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.1631, Safe Access to Cash Act of 2025 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 Notice of Proposed Rulemaking for Debit Card Interchange Fees and Routing (Reg II) Federal Reserve Discount Window and Emergency Lending Authority Tokenization of Assets Fraud Issues Regulatory Tailoring Peer-To-Peer Payment Fraud Financial Data Transparency Act Rulemaking FDIC Brokered Deposit Proposal S. 1467/H.R. 2808 Homebuyers Privacy Protection Act S.J.Res.13, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency of the Department of the Treasury relating to the review of applications under the Bank Merger Act H.J.Res.92 - Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency of the Department of the Treasury relating to the review of applications under the Bank Merger Act. 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.3390 - Bringing the Discount Window into the 21st Century 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

Protect the credit union tax exemption Support legislation and regulation that advance credit unions and their over 142 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 Support regulatory framework for artificial intelligence that allows responsible innovation and recognizes compliance with existing regulations Support mandatory arbitration agreements Oppose national 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 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 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 childcare expenses for federal credit union board meetings 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 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 action to reduce scope of supervisory committee examination 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 making CFPB subject to regular appropriations process 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 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 Support exemptions for CFPB Section 1071 final rule Oppose CFPB rule on overdraft for very large financial institutions Oppose CFPB proposed rule on NSF fees Oppose CFPB efforts to restrict information in credit reports Oppose CFPB credit card penalty fees final rule Oppose CFPB Section 1071 final rule Oppose CFPB Section 1033 final rule Oppose prohibition on use of medical debt information in credit decisions 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 under the Fair Credit Reporting Act/Regulation V Support consumer protection regulations for buy-now-pay-later loan providers 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 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 Regulation II debit interchange fee cap Oppose Federal Reserve proposed rule on modifying Regulation II debit interchange cap Oppose legislative action to impose caps or restrictions on debit or credit interchange fees 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 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 parity for credit union provision of digital asset services Prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products Support parity for credit unions related to stablecoin regulation Oppose treating stablecoins or digital assets as federally insured Support digital assets guardrails to prevent deposit outflows Support clarifying credit unions authority to provide custodial services for their members Support reduced government-sponsored enterprises costs for credit union mortgages Support secondary mortgage market access for credit unions Support credit union access to Federal Home Loan 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 consistency between NCUA and FinCEN requirements on Bank Secrecy Act compliance 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 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 disbursement of all 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 Support enhanced transparency and consumer control of financial data 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 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 Guiding and Establishing National Innovation for U.S. Stablecoins Act (S. 394, S. 919, S. 1582) Support Stablecoin Transparency and Accountability for a Better Ledger Economy Act (H.R. 2392) Support Making the CFPB Accountable to Small Businesses Act (H.R. 1606) Support Financial Integrity and Regulation Management Act (S. 875; H.R. 2702) 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) 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) 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 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 (S. 2019) Support Capping Excessive Awarding of SBLC Entrants Act (H.R. 2987) Support Expanding Access to Lending Options Act (H.R. 4167) Support parity for credit unions in Digital Asset Market Clarity Act (H.R. 3633) Support changes to CFPB funding, creation of investment accounts for children, and auto loan interest deduction in H.R. 1 Support Congressional Review Act resolution of disapproval of the CFPB overdraft rule (H.J.Res. 59; S.J.Res. 18) Support Congressional Review Act resolution of disapproval of the CFPB medical debt rule (H.J.Res. 74; S.J.Res. 36) 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)

H.R.736 - To amend title 31, United States Code, to modify the deadline for filing beneficial ownership information reports for reporting companies formed or registered before January 1, 2024. H.R.807 - To direct the Secretary of the Treasury to submit a report on coordination in the public and private sectors in responding to ransomware attacks on financial institutions, and for other purposes. H.R.2331 - To enhance rulemaking requirements for the Bureau of Consumer Financial Protection, and for other purposes.

Client expense: $424,512 · 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 142 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 modifying the credit union member business lending cap Support financial inclusion and increased access to financial services Support NCUAs existence as an independent regulator and insurer of credit unions Support assistance for minority depository institution credit unions Support harmonization of federal cyber incident notification standards Oppose Community Reinvestment Act requirements for credit unions Support regulatory framework for artificial intelligence that allows responsible innovation and recognizes compliance with existing regulations Support mandatory arbitration agreements Oppose national 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 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 Oppose NCUA disclosure of credit union overdraft and NSF fee revenue data 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 childcare expenses for federal credit union board meetings Oppose NCUA acting as a climate regulator Oppose NCUA rule on succession planning 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 action to reduce scope of supervisory committee examination 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 making CFPB subject to regular appropriations process 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 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 Support exemptions for CFPB Section 1071 final rule Oppose CFPB rule on overdraft for very large financial institutions Oppose CFPB proposed rule on NSF fees Oppose CFPB efforts to restrict information in credit reports Oppose CFPB credit card penalty fees final rule Oppose CFPB Section 1071 final rule Oppose CFPB Section 1033 final rule Oppose prohibition on use of medical debt information in credit decisions Oppose CFPB rulemaking activity before transition in administrations 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 under the Fair Credit Reporting Act/Regulation V Support consumer protection regulations for buy-now-pay-later loan providers 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, and does not authorize private right of action 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 Regulation II debit interchange fee cap Oppose Federal Reserve proposed rule on modifying Regulation II debit interchange cap Oppose legislative action to impose caps or restrictions on debit or credit interchange fees 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 parity for credit union provision of digital asset services Prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products Support parity for credit unions related to stablecoin regulation Support reduced government-sponsored enterprises costs for credit union mortgages Support secondary mortgage market access for credit unions Support credit union access to Federal Home Loan 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 consistency between NCUA and FinCEN requirements on Bank Secrecy Act compliance Support DOD clarification of Military Lending Act and Servicemembers Civil Relief Act requirements Oppose nominal leases for banks on military installations Oppose legislative action on the Overseas Military Banking Program 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 disbursement of Community Development Financial Institution Fund awards Support timely completion of Emergency Capital Investment Program disposition agreements 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 Guiding and Establishing National Innovation for U.S. Stablecoins Act (S. 394, S. 919) Support Stablecoin Transparency and Accountability for a Better Ledger Economy Act (H.R. 2392) Support Making the CFPB Accountable to Small Businesses Act (H.R. 1606) Support Financial Integrity and Regulation Management Act (S. 875) 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) 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) Support Increasing Credit Union Lending for Business Growth Act (H.R. 1791) Support Financial Reporting Threshold Modernization Act (H.R. 1799) Support Home of Your Own Act (H.R. 2064) Support HELPER 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 Congressional Review Act resolution of disapproval of the CFPB overdraft rule (H.J.Res. 59; S.J.Res. 18) Support Congressional Review Act resolution of disapproval of the CFPB medical debt rule (H.J.Res. 74; S.J.Res. 36) Support draft Consumer Financial Protection Commission Act Oppose 10 Percent Credit Card Interest Rate Cap Act (H.R. 1944; S. 381)