FIRM Act

Met with the House and Senate on preemption issues Met with the House and Senate on issues impacting large global banks Met with the House and Senate on digital assets Met with the House and Senate on sanctions legislation Met with the House and Senate on market regulations Met with the House and Senate on bank capital regulations Met with the House and Senate on credit card pricing Met with the House and Senate on AML regulations Met with the House and Senate on geopolitical issues impacting the global economy, including China Met with the House and Senate on proposals related to outbound investment Met with the House and Senate on artificial intelligence Met with the House and Senate on fair access to banking issues and legislative proposals Met with the House and Senate on cybersecurity issues Met with the House and Senate on interchange issues/previously introduced Credit Card Competition Act Met with the House and Senate on bank supervision issues Met with the House and Senate on proposals related to deposit insurance Met with the House and Senate on proposals to revalue and demonetize U.S. gold reserves Met with the House on Federal Reserve master account issues Draft legislation - Banking Regulator Accountability Act - all provisions H.R.2392, Stablecoin Transparency and Accountability for a Better Ledger Economy Act of 2025 - all provisions H.R.2548/S.1241, Sanctioning Russia Act of 2025 - all provisions H.R.3633, Market Structure Clarity Act of 2025 - all provisions H.R.8395, PACE Act of 2026 - all provisions S.401/H.R.987, Fair Access to Banking Act - all provisions S.875/H.R.2702, Financial Integrity and Regulation Management (FIRM) Act - all provisions S.2381/H.R.1944, the 10 Percent Credit Card Interest Rate Cap Act - all provisions S.2999/S.4198, the Main Street Depositors Protection Act - all provisions

Client expense: $1,330,000 · Firm income: Not reported

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

H.R. 478/S. 113, Promoting New Bank Formation Act S. 875/H.R. 2702, Financial Integrity and Regulation Management (FIRM) Act H.R. 1919/S. 1124, the Anti-CBDC Surveillance State Act H.R. 976/S. 557, the 1071 Repeal to Protect Small Business Lending Act H.R. 2392, the Stablecoin Transparency and Accountability for a Better Ledger Economy Act of 2025 (STABLE Act) S. 394/ S.919, Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS) S.3623/H.R.7035, Credit Card Competition Act of 2026 H.R. 1944/S. 381, the 10 Percent Credit Card Interest Rate Cap Act H.R. 654, the Taking Account of Bureaucrats Spending (TABS) Act of 2025 H.R. 987/S. 401, the Fair Access to Banking Act H.R. 1652, the Rectifying UDAAP Act H.R. 3445, the Bureau of Consumer Financial Protection Commission Act H.R. 1653, the CID Reform Act Business of Insurance Regulatory Reform Act H.R. 2513, CFPB-IG Reform Act H.R. 2183, the CFPB Dual Mandate and Economic Analysis Act H.R. 2331, the Transparency in CFPB Cost-Benefit Analysis Act H.R. 1606, the Making the CFPB Accountable to Small Business Act Cybersecurity Information Sharing Act Community Development Financial Institutions (CDFI) Fund Secure and Fair Enforcement (SAFE) Banking Act Regulatory Tailoring Community Reinvestment Act Deposit Insurance Reform S.4198/H.R.8087, the Main Street Depositor Protection Act National Bank Preemption H.R. 306, the Ending Scam Credit Repair Act Bank On Certification Program Central Bank Digital Currency Cryptocurrency Stablecoin Digital Assets Bank Capital Requirements/Basel Capital Proposal UDAAP Supervisory Policies and Adjudication Procedures Applying Community Reinvestment Act to credit unions Merchant Category Codes H.R. 1181, Protecting Privacy in Purchases Act H.R.1602, Financial Privacy Act of 2025 Foreign Affiliate Sharing Pilot Program Extension Act Financial Innovation and Technology for the 21st Century Act H.R.2885, Bank Loan Privacy Act H.R. 941, Small Lender Act Regulation II: Debit Card Interchange Fees and Routing Implementation of Dodd-Frank Act Section 1033: Final Rule on Personal Financial Data Rights Merger and Acquisition Policy Artificial Intelligence Risk Management, Regulation, and Innovation CDFI Certification & Funding Federal Reserve Discount Window and Emergency Lending Authority Tokenization of Assets Fraud Issues Peer-To-Peer Payment Fraud Financial Data Transparency Act Rulemaking FDIC Brokered Deposit Proposal H.R. 3633, the Digital Asset Market Clarity (CLARITY) Act of 2025 H.R.1900 - Bank Failure Prevention Act of 2025 H.R.3230 - Financial Institution Regulatory Tailoring Enhancement Act H.R.8287 - Stress Testing Accountability and Transparency Act H.R. 2835, the Small Bank Holding Company Relief Act H.R. 3709, the Advancing the Mentor-Protege Program for Small Financial Institutions Act H.R. 3716, the Systemic Risk Authority Transparency Act H.R. 940, the Fair Audits and Inspections for Regulators' (FAIR) Exams Act H.R. 3379, the Halting Uncertain Methods and Practices in Supervision (HUMPS) Act of 2025 H.R. 3380, the Taking Account of Institutions with Low Operation Risk (TAILOR) Act of 2025 S.2019 - Task Force for Recognizing and Averting Payments Scams (TRAPS) Act H.R. 3390, the Bringing the Discount Window into the 21st Century Act H.R. 4460, the Stop Agency Fiat Enforcement of Guidance (SAFE Guidance) Act H.R. 3446, the FDIC Board Accountability Act H.R. 4544, The American Access to Banking Act H.R. 4478, the Tailored Regulatory Updates for Supervisory Testing Act of 2025 (TRUST Act) H.R. 4437, the Supervisory Modifications for Appropriate Risk-Based Testing Act of 2025 (SMART Act) H.R. 5270, the Stress Testing Accountability and Transparency Act H.R. 5276, the Community Bank Leverage Improvement and Flexibility for Transparency (Community Bank LIFT) Act H.R. 5291, the Merchant Banking Modernization Act H.R. 5262, the Bank Competition Modernization Act Legislation to support Minority Depository Institutions H.R. 6553, the Tailoring and Indexing Enhanced Regulations (TIER) Act H.R. 6554, the Community Bank Representation Act H.R. 6536, Rural Depositories Revitalization Study Act H.R. 6551, the New Bank Application Numbers Knowledge Act (New BANK) Act H.R. 6546, Merger Process Review Act H.R. 6570, the Merger Agreement Approvals Clarity and Predictability Act H.R. 6544, The Regulatory Efficiency, Verification, Itemization, and Enhanced Workflow (REVIEW) Act H.R. 6550, the American Financial Institution Regulatory Sovereignty and Transparency (American FIRST) Act H.R. 6555, the Enhancing Bank Resolution Participation Act Ensuring Fair Access to Banking Act H.R. 6955, the Main Street Capital Access Act H.R. 7056, the Community Bank Regulatory Tailoring Act S.3940, the Access to Fair Financing for Opportunity and Resilient Development (AFFORD) Act S. 3017, the STREAMLINE Act H.R. 1799, the Financial Reporting Threshold Modernization Act H.R. 8278, Fostering the Use of Technology to Uphold Regulatory Effectiveness in Supervision (FUTURES) Act H.R. 9331, the Strengthening Transaction Oversight Preventing (STOP) Payments Fraud Act H.R. 9471/S. 4942, the Secure and Fair Enforcement Banking Act (SAFE Banking Act) of 2026 H.R. 8395, the Payments Access and Consumer Efficiency (PACE) Act

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

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

H.R. 306 / S. 4144 - Ending Scam Credit Repair Act: provisions related to credit reporting reform. H.R. 940 - Fair Audits and Inspections for Regulators' (FAIR) Exams Act: provisions related to examination. H.R. 2152 - Artificial Intelligence Practices, Logistics, Actions, and Necessities (AI PLAN) Act; provisions related to artificial intelligence. H.R. 2702 / S. 875 - Financial Integrity and Regulation Management (FIRM) Act: provisions related to regulatory reform. H.R. 2978 - Guarding Unprotected Aging Retirees from Deception (GUARD) Act; provisions related to artificial intelligence. H.R. 3380 / S. 427 - Taking Account of Institutions with Low Operation Risk (TAILOR) Act of 2025: provisions related to regulatory reform. H.R. 3709 - Advancing the Mentor-Protege Program for Small Financial Institutions Act: provisions related to regulatory reform. H.R. 4801 - Unleashing AI Innovation in Financial Services Act; provisions related to artificial intelligence. H.R. 4437 - Supervisory Modifications for Appropriate Risk-based Testing (SMART) Act: provisions related to examination. H.R. 4478 / S. 3830 - Tailored Regulatory Updates for Supervisory Testing (TRUST) Act of 2025 Act: provisions related to examination. H.R. 5317 - Community Bank Deposit Access Act of 2025: provisions regarding custodial deposits. H.R. 5402 / S. 1465 - Credit Access and Inclusion Act of 2025: provisions related to credit reporting. H.R. 6552 - Bank-Fintech Partnership Enhancement Act: provisions related to bank-fintech partnerships. H.R. 6955 - Main Street Capital Access Act: provisions from proposed bills H.R. 940, H.R. 2702, H.R. 4437, H.R. 5317 and S. 875. H.R. 7866 / S.3889 - American Lending Fairness Act of 2026: provisions related to lending. H.R. 8278 - Fostering the Use of Technology to Uphold Regulatory Effectiveness in Supervision (FUTURES) Act; provisions related to artificial intelligence. H.R. 8398 - Guidelines for Use, Access, and Responsible Disclosure of Financial Data Act; provisions related to artificial intelligence. H.R. 8671 - Bank Fraud Technology Advancement Act of 2026; provisions related to artificial intelligence. H.R. 9330 - Earned Wage Access Consumer Protection Act; provisions related to earned wage access. H.R. 9331 - STOP Payments Fraud Act of 2026; provisions related to regulatory reform. S. 1582 - Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act; provisions related to interest/yield reform. S. 3721 - Empowering States Rights To Protect Consumers Act of 2026: provisions related to lending. Discussions regarding modernization of the Gramm-Leach-Bliley Act, Title VI.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Protect the credit union tax exemption Support legislation and regulation that advance credit unions and their over 146 million members Support regulatory relief for credit unions Support holistic evaluation of regulatory burden on credit unions Support modification of credit union loan maturity limits Support credit union field of membership expansion and modernization Support regulator- and bank-approved credit union-bank mergers Support financial inclusion and increased access to financial services Support modifying the credit union member business lending cap Support NCUAs existence as an independent regulator and insurer of credit unions Support assistance for minority depository institution credit unions Support regulatory relief for de novo credit unions Support harmonization of federal cyber incident notification standards Oppose Community Reinvestment Act requirements for credit unions Oppose legislative action to restrict credit union overdraft and courtesy pay programs Support regulatory framework for artificial intelligence that allows responsible innovation and recognizes credit unions compliance with existing regulations Support allowing use of artificial intelligence for regulatory reporting purposes Support mandatory arbitration agreements Oppose national interest rate cap Oppose national credit card interest rate cap Support expanded natural person and corporate credit union investment authority Support expanded credit union examination cycle Support increased examination transparency Support regulatory policies to promote innovation and access to credit Support Central Liquidity Facility and Community Development Revolving Loan Fund enhancements Oppose NCUA examination of credit union vendors Oppose National Credit Union Share Insurance Fund structural changes or premium assessment Support parity in deposit insurance coverage levels between credit unions and banks Oppose additional Call Report fields on loans to credit union officials and senior executive staff Oppose additional Call Report fields on maturity distribution of uninsured shares Oppose making changes to Call Report requirements without using notice-and-comment process Oppose NCUA Call Report collection of overdraft and NSF fee revenue data Support modernization and simplification of Call Report form and instructions Support rescission of NCUA overdraft and NSF fee guidance Oppose collection of vendor information in NCUA Credit Union Profile Oppose changes to NCUA collection forms outside rulemaking process Support NCUA review of normal operating level and methodology Support NCUA action to permit credit union reimbursement of dependent care expenses for federal credit union official duties Oppose NCUA rule on succession planning Support modification of NCUA record retention requirements Oppose excessive NCUA requirements for supervisory committee audits Support NCUA action to reduce scope of supervisory committee examination Support NCUA recognition of digital banking in service facility definition Support clarification of NCUA member expulsion regulations Support NCUA proposed rule on increasing overdraft flexibility Support NCUA recognition of government sponsored enterprises as government agencies for loan maturity limit purposes Support NCUA adoption of floating interest rate cap Support modification of NCUA commercial loan definition Support increased flexibility in NCUA occupancy requirements Support NCUA action to clarify loan participation limits Support NCUA modification of low-income designation process Support expanding NCUA qualified charity definition Support allowing greater weighted average life for corporate credit unions financial assets Support extension of maturity limit for corporate credit union borrowing Support increased flexibility for advertising and notice of insured status Support increased compliance timeline for NCUA simplification of share insurance rule Support removing reputational risk as a component of credit union examinations Support balanced implementation of debanking executive order Support increased NCUA efforts to promote credit union industry Support modernization and streamlining of NCUA operations Support NCUA supervisory flexibility for credit union shutdown assistance efforts Support NCUA action to modernize CAMELS rating system Support modernization of NCUA fidelity bond review requirements Support making CFPB subject to regular appropriations process Support increased CFPB budget transparency Support restructuring CFPB leadership to a bipartisan commission Support creation of a CFPB Inspector General Support reforms to CFPB Civil Investigative Demand process Support increasing asset thresholds for CFPB supervision of credit unions Support clarification of CFPB unfair, deceptive, or abusive acts and practices authority Support CFPB use of Section 1022 authority to exempt credit unions from certain regulations Support CFPB oversight and monitoring of nonbank entities Oppose CFPB efforts to avoid requirements of the rulemaking process Support CFPB use and disclosure of relevant data in rulemakings Support CFPB use of cost-benefit analysis in rulemaking process Support CFPB coordination with NCUA on policy matters and examination scheduling Oppose mislabeling financial services fees as junk fees Oppose arbitrary limits on credit union fee income Oppose CFPB efforts to restrict information in credit reports Support CFPB engaging in ongoing retrospective review of past regulations Support CFPB consumer complaint database reforms Support CFPB no-action letter program with extended timeline and increased protection of sensitive strategic information Oppose expansion of consumer report and consumer reporting agency definitions under the Fair Credit Reporting Act/Regulation V Support consumer protection regulations for buy-now-pay-later loan providers Support inclusion of buy-now-pay-later loans in FHA underwriting Support CFPB use of Civil Penalty Fund for consumer financial education Support increase of Home Mortgage Disclosure Act reporting thresholds Support removal of disparate impact analysis from Regulation B and modification of discouragement standard Support credit union access to universal service fund letters of credit program Support recognition of unique credit union structure in Financial Data Transparency Act joint data standards Support federal data privacy and security standard that exempts Gramm-Leach-Bliley Act covered institutions, preempts state laws, operates on an opt-out basis, recognizes the complexity of data deletion, and does not authorize private right of action Support increased transparency for fintech bank charter applications Support Treasury development of model forms and qualified vehicle list for auto loan interest deduction Support safe harbor for credit unions related to the auto loan interest deduction Support clarification of remittance transfer tax exemptions Support inclusion of credit unions in Trump Accounts program Oppose development of a central bank digital currency Support credit union access to Federal Reserve liquidity options Support gradual expansion of Fedwire and National Settlement Service operating hours with optional participation Oppose addition of fourth same-day ACH window Support expanded flexibility for accessing the Fed discount window and intraday credit Oppose expanded eligibility for Federal Reserve master account access Oppose Regulation II debit interchange fee cap Oppose Federal Reserve proposed rule on modifying Regulation II debit interchange cap Support improvements to the Federal Reserves Debit Card Issuer Survey Oppose legislative action to impose caps or restrictions on debit or credit interchange fees Oppose legislative action to prohibit the Federal Reserve from paying interest on reserves Support Federal Reserve action to coordinate regulatory guidance on penny circulation issues and management of penny supply Support continued offering of Federal Reserve check services Oppose expansion of Electronic Fund Transfer Act/Regulation E financial institution liability Support fair distribution of Electronic Fund Transfer Act/Regulation E error resolution responsibilities Support clarification of funds definition under Electronic Fund Transfer Act/Regulation E Support clarification of Electronic Fund Transfer Act/Regulation E treatment of digital assets Support increased flexibility for check holds and funds availability requirements Support transition to electronic payments for government payments Support consumer education on transition to electronic payments Support clarification of Section 314(b) information sharing safe harbor for identifying and preventing payments fraud Support greater flexibility for credit unions to decline services with clear indica of fraud or elder abuse Support parity for credit union provision of digital asset services Prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products Support Treasury and NCUA action to implement regulatory framework for stablecoin issuance Support parity for credit unions related to stablecoin regulation Support NCUAs role as primary regulator of credit unions stablecoin activities Oppose treating stablecoins or digital assets as federally insured Oppose payment of interest, yield, or rewards on stablecoin holdings Support digital assets guardrails to prevent deposit outflows Support clarifying credit unions authority to provide custodial services for their members Support safeguards for rehypothecation of digital assets Support reduced government-sponsored enterprises costs for credit union mortgages Support secondary mortgage market access for credit unions Support continued role for FHFA as an independent regulator Support credit union access to Federal Home Loan Bank system Support expansion of Federal Home Loan Bank Act community financial institution definition Support Federal Home Loan Bank engagement with credit unions Oppose adoption of volume-based incentives for Federal Home Loan Banks Support Federal Home Loan Bank allocations to the Affordable Housing Program Support FinCEN implementation of the Corporate Transparency Act Support additional time to implement anti-money laundering/countering financing of terrorism program changes and publication of guidance Support increasing Currency Transaction Report and Suspicious Activity Report filing thresholds Support streamlining Currency Transaction Report and Suspicious Activity Report forms Support increased inclusion of identifiable information in Section 314(a) information requests Support consistency between NCUA and FinCEN requirements on Bank Secrecy Act compliance Support FinCEN survey to accurately measure Bank Secrecy Act compliance costs Support DOD clarification of Military Lending Act and Servicemembers Civil Relief Act requirements Support standardized disclosures and financial literacy briefings for servicemembers Support credit union access to nominal leases on military installations Oppose nominal leases for banks on military installations Oppose legislative action on the Overseas Military Banking Program Oppose inclusion of interchange, interest rate cap, or fraud liability amendments in the National Defense Authorization Act Support inclusion of currency transaction report/suspicious activity report thresholds and veterans member business lending amendments in the National Defense Authorization Act Support federal share insurance for all credit unions acting as fiscal agents of the U.S. government Support role of Community Development Financial Institutions Fund in promoting economic growth and access to capital in underserved communities Support access to Community Development Financial Institutions Fund awards and technical assistance for credit unions Support Community Development Financial Institutions Fund bond guarantee program Support Community Development Financial Institutions Fund liquidity enhancement pilot program Support disbursement of all Community Development Financial Institution Fund appropriated award funding without additional barriers Support timely completion of Emergency Capital Investment Program disposition agreements Oppose reclassification of credit header information as a consumer report Oppose reliance on single source of documentation to determine instances of identity theft or coerced debt Oppose use of interim final rule to modify personal financial data rights requirements Support modification of Section 1033 rule to allow data providers to charge fees, remove prescriptive technology standards, and establish data privacy standards and allocation of liability Support increased reporting and small business revenue threshold and elimination of discretionary data points collection in revised Section 1071 rule Support modernization of e-signature requirements Support allowing electronic or documented oral credit card applications Support increased flexibility for disclosures Support rescission of CFPB payday lending rule payment provisions Support modification of FCC revocation of consent rule Support greater flexibility for FCC fraud alert exemption Support uniform federal standards and increased federal preemption of state laws on interchange, data privacy, artificial intelligence, and elder financial abuse reporting Support federal safe harbor for provision of financial services to marijuana-related businesses that comply with state laws Issues related to housing finance reform Issues related to flood insurance Issues related to privately insured credit unions Issues related to credit union capital requirements Issues related to credit union conversions Issues related to credit unions as employers Issues related to the Foreign Account Tax Compliance Act Issues related to fair lending Issues related to the Telephone Consumer Protection Act Support nomination of John Crews as a member of the NCUA Board Support Credit Union Board Modernization Act (H.R. 975; S. 522) Support 1071 Repeal to Protect Small Business Lending Act (H.R. 976; S. 557) Support Making the CFPB Accountable to Small Businesses Act (H.R. 1606) Support Financial Integrity and Regulation Management Act (S. 875; H.R. 2702; Senate Amendment 3104) Support Fair Audits and Inspections for Regulators Act (H.R. 940) Support Small LENDER Act (H.R. 941) Support Anti-CBDC Surveillance State Act (H.R. 1919; S. 1124) Support Veterans Member Business Loan Act (H.R. 507; S. 110; Senate Amendment 3776) Support Taking Account of Bureaucrats Spending Act (H.R. 654) Support Rectifying UDAAP Act (H.R. 1652) Support Civil Investigative Demand Reform Act (H.R. 1653) Support SECURE Notarization Act (H.R. 1777; S. 1561) Support Increasing Credit Union Lending for Business Growth Act (H.R. 1791) Support Financial Reporting Threshold Modernization Act (H.R. 1799; Amendment 715 to H.R. 3838) Support Home of Your Own Act (H.R. 2064) Support Homes for Every Local Protector, Educator, and Responder Act (H.R. 2094; S. 978) Support CFPB Dual Mandate and Economic Analysis Act (H.R. 2183) Support Transparency in CFPB Cost-Benefit Analysis Act (H.R. 2331) Support CFPB-IG Reform Act (H.R. 2513) Support Homebuyers Privacy Protection Act (H.R. 2808; S. 1467) Support Financial Institution Regulatory Tailoring Enhancement Act (H.R. 3230) Support Halting Uncertain Methods and Practices in Supervision Act (H.R. 3379) Support Taking Account of Institutions with Low Operation Risk Act (H.R. 3380) Support Bureau of Consumer Financial Protection Commission Act (H.R. 3445) Support Advancing the Mentor-Protege Program for Small Financial Institutions Act (H.R. 3709) Support Expanding Access to Lending Options Act (H.R. 4167) Support CDFI Bond Guarantee Program Improvement Act (S. 1880) Support Taskforce for Recognizing and Averting Payment Scams Act (H.R. 4936; S. 2019; Senate Amendment 3257) Support Capping Excessive Awarding of SBLC Entrants Act (H.R. 2987) Support Expanding Access to Lending Options Act (H.R. 4167) Support Supervisory Modifications for Appropriate Risk-Based Testing Act (H.R. 4437) Support Stop Agency Fiat Enforcement Act (H.R. 4460) Support American Access to Banking Act (H.R. 4544) Support Protecting Access to Credit for Small Businesses Act (S. 2486) Support Business of Insurance Regulatory Reform Act (H.R. 4735; S. 2419) Support NCUA Central Liquidity Facility Enhancement Act (S. 2545, S. 3575; Senate Amendments 3722, 3834, 4384, 5882, 6180) Support CDFI Fund Transparency Act (S. 2704; Senate Amendments 3640, 3732) Support Supporting Upgraded Property Projects and Lending for Yards Act (H.R. 4568) Support Unleashing AI Innovation in Financial Services Act (H.R. 4801) Support AI Practices, Logistics, Actions, and Necessities Act (H.R. 2152) Support Streamlining Transaction Reporting and Ensuring Anti-Money Laundering Improvements for a New Era Act (S. 3017; Senate Amendment 6241) Support NFIP Continuation Act (H.R. 5577) Support 21st Century ROAD to Housing Act (H.R. 6644) Support Regulatory Efficiency, Verification, Itemization, and Enhanced Workflow Act (H.R. 6544) Support Community Bank Regulatory Tailoring Act (H.R. 7056) Support Close the Shadow Banking Loophole Act (S. 3734) Support American Lending Fairness Act (S. 3889; H.R. 7866) Support Community Bank Relief Act (S. 3849; H.R. 7484) Support Access to Fair Financing for Opportunity and Resilient Development Act (Senate Amendments 4354, 4394, 6101; S. 3940) Support Growing Deposit Insurance for the Future Act (H.R. 8088) Support ESCRA Act (H.R. 306) Support Credit Access and Inclusion Act (H.R. 5402; S. 1465) Support FCRA Liability Harmonization Act (H.R. 5775) Support Guarding Unprotected Aging Retirees from Deception Act (H.R. 2978; S. 2544; Senate Amendment 6471) Support Eliminating Fraud in the CFPBs Complaint Database Act (H.R. 7588) Support Fair Credit Reporting Reseller Accuracy Act (H.R. 8141) Support Bank Fraud Technology Advancement Act (H.R. 8671) Support STOP Payments Fraud Act (H.R. 9331) Support emergency transaction account guarantee legislation (H.R. 8075) Support inclusion of guidance on penny circulation and rounding in Common Cents Act (H.R. 3074) Support parity for credit unions and prohibition on stablecoin yield in Digital Asset Market Clarity Act (H.R. 3633) Support modification of Section 705 in Renewing Opportunity in the American Dream to Housing Act (S. 2651) Support inclusion of credit union parity provisions in Main Street Capital Access Act (H.R. 6955) Oppose Repealing Big Brother Overreach Act (H.R. 425; S. 100) Oppose 10 Percent Credit Card Interest Rate Cap Act (H.R. 1944; S. 381; Senate Amendment 2239) Oppose Credit Card Competition Act (Senate Amendments 2229, 2230, 2345, 4305; S. 3623; H.R. 7035) Oppose commissary interchange fee study (Senate Amendment 3216) Oppose commissary coupon pilot program (Senate Amendments 5942, 6034) Oppose End the Feds Big Bank Bailout Act (S. 2113; Senate Amendment 3761) Oppose Credit Card Fairness Act (S. 3660) Oppose S.J.Res. 130, on CFPB overdraft circular Oppose S.J.Res. 132, on CFPB examinations for risks to servicemembers Oppose S.J.Res. 141, on deceptive collection of medical debt

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

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

All legislation related to consumer lending regulation and consumer lending policy. Issues related to de-risking. S. 875, The Financial Integrity and Regulation Management Act. H.R. 2702, The Financial Integrity and Regulation Management Act. S. 2781,The Protecting Consumers from Unreasonable Credit Rates Act. S. 2326, The Payment Choice Act of 2025. H.R. 1138, The Payment Choice Act of 2025. S. 3793, The Predatory Lending Elimination Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 654, TABS Act of 2025 H.R. 940, Fair Audits and Inspections for Regulators (FAIR) Exams Act H.R. 1602, Financial Privacy Act of 2025 H.R. 1900, Bank Failure Prevention Act of 2025 H.R. 2702/S. 875, Financial Integrity and Regulation Management (FIRM) Act H.R. 3230, Financial Institution Regulatory Tailoring Enhancement Act H.R. 3379, Halting Uncertain Methods and Practices in Supervision Act of 2025 H.R. 3380, Taking Account of Institutions with Low Operation Risk (TAILOR) Act of 2025 H.R. 3390, Bringing the Discount Window into the 21st Century Act H.R. 3446, FDIC Board Accountability Act H.R. 4437, Supervisory Modifications for Appropriate Risk-based Testing (SMART) Act of 2025 H.R. 4478, Tailored Regulatory Updates for Supervisory Stress Testing (TRUST) Act of 2025 H.R. 5270, Stress Testing Accountability and Transparency Act H.R. 5291/S. 2663, Merchant Banking Modernization Act H.R. 6955, Main Street Capital Access Act H.R. 7056, Community Bank Regulatory Tailoring Act S. 3772, Export-Import Bank Reauthorization Act of 2026 H.J. Res. 59/S.J. Res. 18, Disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Overdraft Lending: Very Large Financial Institutions" H.J. Res. 64/S.J. Res. 28, Disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications" H.J. Res. 74/S.J. Res. 36, Disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information (Regulation V)" Draft legislation to amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to repeal certain rulemaking requirements Draft legislation in the House of Representatives to Reauthorize the Export-Import Bank of the United States Potential legislation regarding the funding of the Consumer Financial Protection Bureau Proposed Rule, Consumer Financial Protection Bureau; Overdraft Lending: Very Large Financial Institutions (89 Fed. Reg. 13,852-13,908, February 23, 2024) Proposed Rule, Federal Deposit Insurance Corporation, Statement of Policy on Bank Merger Transactions (89 Fed. Reg. 29,222-29,244, June 18, 2024) Proposed Rule, Consumer Financial Protection Bureau: Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information (Regulation V) (89 Fed. Reg. 51,682-51,736, June 18, 2024) Proposed Rule, Consumer Financial Protection Bureau; Protecting Americans from Harmful Data Broker Practices (Regulation V) (88 Fed. Reg. 101,402-101,462, December 13, 2024) Advance Notice of Proposed Rulemaking, Consumer Financial Protection Bureau; Fair Credit Reporting Act (Regulation V); Identity Theft and Coerced Debt (89 Fed. Reg. 100,922-100,923, December 13, 2024) Final Rule, Consumer Financial Protection Bureau; Credit Card Penalty Fees (Regulation Z) (89 Fed. Reg. 19,128-19,223, March 15, 2024) Proposed Rule, Consumer Financial Protection Bureau; Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications (88 Fed. Reg. 80,197-80,216, November 17, 2023) Proposed Rule, Federal Reserve Board: Modifications to the Capital Plan Rule and Stress Capital Buffer Requirement (90 Fed. Reg. 16,843-16,860, April 22, 2025) Proposed Rule, Consumer Financial Protection Bureau; Equal Credit Opportunity Act (Regulation B) (90 Fed. Reg. 50,901-50,923, October 13, 2025) Proposed Rule, Revised Guidelines, Office of the Comptroller of the Currency, Guidelines Establishing Heightened Standards for Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches; Technical Amendments (90 Fed. Reg. 61,084-61,093, December 30, 2025) Proposed Rule, Office of the Comptroller of the Currency, Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the Office of the Comptroller of the Currency (91 Fed. Reg. 10,202-10,303, March 2, 2026) Request for Comment, Consumer Financial Protection Bureau, Consumer Response Intake Form (91 Fed. Reg. 4,066-4,067, January 30, 2026) Request for Comment, Consumer Financial Protection Bureau, Draft Strategic Plan for FY 2026-2030 Various issues relating to Regulatory Capital Rules: Regulatory Capital, Implementation of Basel III, Capital Adequacy, Transition Provisions, Prompt Corrective Action, Standardized Approach for Risk-weighted Assets, Market Discipline and Disclosure Requirements, Advanced Approaches Risk-Based Capital Rule, and Market Risk Capital Rule; potential rulemaking regarding Section 956 of the Dodd-Frank Act (P.L. 111-203); independent monetary policy by the Federal Reserve System

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

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

Met with the House and Senate on preemption issues Met with the House and Senate on issues impacting large global banks Met with the House and Senate on digital assets Met with the House and Senate on sanctions legislation Met with the House and Senate on market regulations Met with the House and Senate on bank capital regulations Met with the House and Senate on credit card pricing Met with the House and Senate on AML regulations Met with the House and Senate on geopolitical issues impacting the global economy, including China Met with the House and Senate on proposals related to outbound investment Met with the House and Senate on artificial intelligence Met with the House and Senate on fair access to banking issues and legislative proposals Met with the House and Senate on cybersecurity issues Met with the House and Senate on interchange issues/previously introduced Credit Card Competition Act Met with the House and Senate on bank supervision issues Met with the House and Senate on proposals related to deposit insurance Met with the House and Senate on proposals to revalue and demonetize U.S. gold reserves Met with the House on Federal Reserve master account issues Draft legislation - Banking Regulator Accountability Act - all provisions H.R.2392, Stablecoin Transparency and Accountability for a Better Ledger Economy Act of 2025 - all provisions H.R.2548/S.1241, Sanctioning Russia Act of 2025 - all provisions H.R.3633, Market Structure Clarity Act of 2025 - all provisions S.401/H.R.987, Fair Access to Banking Act - all provisions S.875/H.R.2702, Financial Integrity and Regulation Management (FIRM) Act - all provisions S.2381/H.R.1944, the 10 Percent Credit Card Interest Rate Cap Act - all provisions S.2999/S.4198, the Main Street Depositors Protection Act - all provisions HOLD - Sruthi re: skinny masters account

Client expense: $1,460,000 · Firm income: Not reported

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

All legislation related to consumer lending regulation and consumer lending policy. Issues related to APR caps and de-risking. S. 875, The Financial Integrity and Regulation Management Act. H.R. 2702, The Financial Integrity and Regulation Management Act. S. 2781,The Protecting Consumers from Unreasonable Credit Rates Act. S. 2326, The Payment Choice Act of 2025. H.R. 1138, The Payment Choice Act of 2025. S. 3793, The Predatory Lending Elimination Act

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 478/S. 113, Promoting New Bank Formation Act S. 875/H.R. 2702, Financial Integrity and Regulation Management (FIRM) Act H.R. 1919/S. 1124, the Anti-CBDC Surveillance State Act H.R. 976/S. 557, the 1071 Repeal to Protect Small Business Lending Act H.R. 2392, the Stablecoin Transparency and Accountability for a Better Ledger Economy Act of 2025 (STABLE Act) S. 394/ S.919, Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS) S.3623/H.R.7035, Credit Card Competition Act of 2026 H.R. 1944/S. 381, the 10 Percent Credit Card Interest Rate Cap Act H.R. 654, the Taking Account of Bureaucrats Spending (TABS) Act of 2025 H.R. 987/S. 401, the Fair Access to Banking Act H.R. 1652, the Rectifying UDAAP Act H.R. 3445, the Bureau of Consumer Financial Protection Commission Act H.R. 1653, the CID Reform Act Business of Insurance Regulatory Reform Act H.R. 2513, CFPB-IG Reform Act H.R. 2183, the CFPB Dual Mandate and Economic Analysis Act H.R. 2331, the Transparency in CFPB Cost-Benefit Analysis Act H.R. 1606, the Making the CFPB Accountable to Small Business Act Cybersecurity Information Sharing Act Community Development Financial Institutions (CDFI) Fund Secure and Fair Enforcement (SAFE) Banking Act Regulatory Tailoring Community Reinvestment Act Deposit Insurance Reform S.4198/H.R.8087, the Main Street Depositor Protection Act National Bank Preemption H.R. 306, the Ending Scam Credit Repair Act Bank On Certification Program Central Bank Digital Currency Cryptocurrency Stablecoin Digital Assets Bank Capital Requirements/Basel Capital Proposal UDAAP Supervisory Policies and Adjudication Procedures Applying Community Reinvestment Act to credit unions Merchant Category Codes H.R. 1181, Protecting Privacy in Purchases Act H.R.1602, Financial Privacy Act of 2025 Foreign Affiliate Sharing Pilot Program Extension Act Financial Innovation and Technology for the 21st Century Act H.R.2885, Bank Loan Privacy Act H.R. 941, Small Lender Act Regulation II: Debit Card Interchange Fees and Routing Implementation of Dodd-Frank Act Section 1033: Final Rule on Personal Financial Data Rights Merger and Acquisition Policy Artificial Intelligence Risk Management, Regulation, and Innovation CDFI Certification & Funding Federal Reserve Discount Window and Emergency Lending Authority Tokenization of Assets Fraud Issues Peer-To-Peer Payment Fraud Financial Data Transparency Act Rulemaking FDIC Brokered Deposit Proposal H.R. 3633, the Digital Asset Market Clarity (CLARITY) Act of 2025 H.R.1900 - Bank Failure Prevention Act of 2025 H.R.3230 - Financial Institution Regulatory Tailoring Enhancement Act H.R.8287 - Stress Testing Accountability and Transparency Act H.R. 2835, the Small Bank Holding Company Relief Act H.R. 3709, the Advancing the Mentor-Protege Program for Small Financial Institutions Act H.R. 3716, the Systemic Risk Authority Transparency Act H.R. 940, the Fair Audits and Inspections for Regulators' (FAIR) Exams Act H.R. 3379, the Halting Uncertain Methods and Practices in Supervision (HUMPS) Act of 2025 H.R. 3380, the Taking Account of Institutions with Low Operation Risk (TAILOR) Act of 2025 S.2019 - Task Force for Recognizing and Averting Payments Scams (TRAPS) Act H.R. 3390, the Bringing the Discount Window into the 21st Century Act H.R. 4460, the Stop Agency Fiat Enforcement of Guidance (SAFE Guidance) Act H.R. 3446, the FDIC Board Accountability Act H.R. 4544, The American Access to Banking Act H.R. 4478, the Tailored Regulatory Updates for Supervisory Testing Act of 2025 (TRUST Act) H.R. 4437, the Supervisory Modifications for Appropriate Risk-Based Testing Act of 2025 (SMART Act) H.R. 5270, the Stress Testing Accountability and Transparency Act H.R. 5276, the Community Bank Leverage Improvement and Flexibility for Transparency (Community Bank LIFT) Act H.R. 5291, the Merchant Banking Modernization Act H.R. 5262, the Bank Competition Modernization Act Legislation to support Minority Depository Institutions H.R. 6553, the Tailoring and Indexing Enhanced Regulations (TIER) Act H.R. 6554, the Community Bank Representation Act H.R. 6536, Rural Depositories Revitalization Study Act H.R. 6551, the New Bank Application Numbers Knowledge Act (New BANK) Act H.R. 6546, Merger Process Review Act H.R. 6570, the Merger Agreement Approvals Clarity and Predictability Act H.R. 6544, The Regulatory Efficiency, Verification, Itemization, and Enhanced Workflow (REVIEW) Act H.R. 6550, the American Financial Institution Regulatory Sovereignty and Transparency (American FIRST) Act H.R. 6555, the Enhancing Bank Resolution Participation Act Ensuring Fair Access to Banking Act H.R. 6955, the Main Street Capital Access Act H.R. 7056, the Community Bank Regulatory Tailoring Act S.3940, the Access to Fair Financing for Opportunity and Resilient Development (AFFORD) Act S. 3017, the STREAMLINE Act H.R. 1799, the Financial Reporting Threshold Modernization Act

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

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

H.R. 654, TABS Act of 2025 H.R. 940, Fair Audits and Inspections for Regulators (FAIR) Exams Act H.R. 1602, Financial Privacy Act of 2025 H.R. 1900, Bank Failure Prevention Act of 2025 H.R. 2702/S. 875, Financial Integrity and Regulation Management (FIRM) Act H.R. 3230, Financial Institution Regulatory Tailoring Enhancement Act H.R. 3379, Halting Uncertain Methods and Practices in Supervision Act of 2025 H.R. 3380, Taking Account of Institutions with Low Operation Risk (TAILOR) Act of 2025 H.R. 3390, Bringing the Discount Window into the 21st Century Act H.R. 3446, FDIC Board Accountability Act H.R. 4437, Supervisory Modifications for Appropriate Risk-based Testing (SMART) Act of 2025 H.R. 4478, Tailored Regulatory Updates for Supervisory Stress Testing (TRUST) Act of 2025 H.R. 5270, Stress Testing Accountability and Transparency Act H.R. 5291/S. 2663, Merchant Banking Modernization Act H.R. 6955, Main Street Capital Access Act H.R. 7056, Community Bank Regulatory Tailoring Act S. 3772, Export-Import Bank Reauthorization Act of 2026 H.J. Res. 59/S.J. Res. 18, Disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Overdraft Lending: Very Large Financial Institutions" H.J. Res. 64/S.J. Res. 28, Disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications" H.J. Res. 74/S.J. Res. 36, Disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information (Regulation V)" Draft legislation to amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to repeal certain rulemaking requirements Draft legislation in the House of Representatives to Reauthorize the Export-Import Bank of the United States Potential legislation regarding the funding of the Consumer Financial Protection Bureau Proposed Rule, Consumer Financial Protection Bureau; Overdraft Lending: Very Large Financial Institutions (89 Fed. Reg. 13,852-13,908, February 23, 2024) Proposed Rule, Federal Deposit Insurance Corporation, Statement of Policy on Bank Merger Transactions (89 Fed. Reg. 29,222-29,244, June 18, 2024) Proposed Rule, Consumer Financial Protection Bureau: Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information (Regulation V) (89 Fed. Reg. 51,682-51,736, June 18, 2024) Proposed Rule, Consumer Financial Protection Bureau; Protecting Americans from Harmful Data Broker Practices (Regulation V) (88 Fed. Reg. 101,402-101,462, December 13, 2024) Advance Notice of Proposed Rulemaking, Consumer Financial Protection Bureau; Fair Credit Reporting Act (Regulation V); Identity Theft and Coerced Debt (89 Fed. Reg. 100,922-100,923, December 13, 2024) Final Rule, Consumer Financial Protection Bureau; Credit Card Penalty Fees (Regulation Z) (89 Fed. Reg. 19,128-19,223, March 15, 2024) Proposed Rule, Consumer Financial Protection Bureau; Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications (88 Fed. Reg. 80,197-80,216, November 17, 2023) Proposed Rule, Federal Reserve Board: Modifications to the Capital Plan Rule and Stress Capital Buffer Requirement (90 Fed. Reg. 16,843-16,860, April 22, 2025) Proposed Rule, Consumer Financial Protection Bureau; Equal Credit Opportunity Act (Regulation B) (90 Fed. Reg. 50,901-50,923, October 13, 2025) Proposed Rule, Revised Guidelines, Office of the Comptroller of the Currency, Guidelines Establishing Heightened Standards for Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches; Technical Amendments (90 Fed. Reg. 61,084-61,093, December 30, 2025) Proposed Rule, Office of the Comptroller of the Currency, Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the Office of the Comptroller of the Currency (91 Fed. Reg. 10,202-10,303, March 2, 2026) Request for Comment, Consumer Financial Protection Bureau, Consumer Response Intake Form (91 Fed. Reg. 4,066-4,067, January 30, 2026) Request for Comment, Consumer Financial Protection Bureau, Draft Strategic Plan for FY 2026-2030 Various issues relating to Regulatory Capital Rules: Regulatory Capital, Implementation of Basel III, Capital Adequacy, Transition Provisions, Prompt Corrective Action, Standardized Approach for Risk-weighted Assets, Market Discipline and Disclosure Requirements, Advanced Approaches Risk-Based Capital Rule, and Market Risk Capital Rule; potential rulemaking regarding Section 956 of the Dodd-Frank Act (P.L. 111-203); independent monetary policy by the Federal Reserve System

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

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

H.R. 306 / S. 4144 - Ending Scam Credit Repair Act: provisions related to credit reporting reform. H.R. 940 - Fair Audits and Inspections for Regulators' (FAIR) Exams Act: provisions related to examination. H.R. 2702 / S. 875 - Financial Integrity and Regulation Management (FIRM) Act: provisions related to regulatory reform. H.R. 3380 / S. 427 - Taking Account of Institutions with Low Operation Risk (TAILOR) Act of 2025: provisions related to regulatory reform. H.R. 3709 - Advancing the Mentor-Protege Program for Small Financial Institutions Act: provisions related to regulatory reform. H.R. 4437 - Supervisory Modifications for Appropriate Risk-based Testing (SMART) Act: provisions related to examination. H.R. 4478 / S. 3830 - Tailored Regulatory Updates for Supervisory Testing (TRUST) Act of 2025 Act: provisions related to examination. H.R. 5317 - Community Bank Deposit Access Act of 2025: provisions regarding custodial deposits. H.R. 5402 / S. 1465 - Credit Access and Inclusion Act of 2025: provisions related to credit reporting. H.R. 6552 - Bank-Fintech Partnership Enhancement Act: provisions related to bank-fintech partnerships. H.R. 6955 - Main Street Capital Access Act: provisions from proposed bills H.R. 940, H.R. 2702, H.R. 4437, H.R. 5317 and S. 875. H.R. 7866 / S.3889 - American Lending Fairness Act of 2026: provisions related to lending. S. 3721 - Empowering States Rights To Protect Consumers Act of 2026: provisions related to lending. Implementation of the interest/yield reform provisions of S. 1582, Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS) Act. Discussions related to the regulatory review process for the Economic Growth and Regulatory Paperwork Reduction Act of 1996. Discussions regarding modernization of the Gramm-Leach-Bliley Act, Title VI. Discussions regarding the proposed reintroduction of the Earned Wage Access Consumer Protection Act. Discussions on potential legislation to modernize credit opportunities related to lending.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Protect the credit union tax exemption Support legislation and regulation that advance credit unions and their over 145 million members Support regulatory relief for credit unions Support holistic evaluation of regulatory burden on credit unions Support credit union field of membership expansion and modernization Support regulator- and bank-approved credit union-bank mergers Support financial inclusion and increased access to financial services Support modifying the credit union member business lending cap Support NCUAs existence as an independent regulator and insurer of credit unions Support assistance for minority depository institution credit unions Support regulatory relief for de novo credit unions Support harmonization of federal cyber incident notification standards Oppose Community Reinvestment Act requirements for credit unions Oppose legislative action to restrict credit union overdraft and courtesy pay programs Support regulatory framework for artificial intelligence that allows responsible innovation and recognizes credit unions compliance with existing regulations Support allowing use of artificial intelligence for regulatory reporting purposes Support mandatory arbitration agreements Oppose national interest rate cap Oppose national credit card interest rate cap Support Federal Credit Union Act modernization Support expanded natural person and corporate credit union investment authority Support expanded credit union examination cycle Support increased examination transparency Support Central Liquidity Facility and Community Development Revolving Loan Fund enhancements Oppose NCUA examination of credit union vendors Support modification of credit union loan maturity limits Oppose National Credit Union Share Insurance Fund structural changes Oppose National Credit Union Share Insurance Fund premium assessment Support parity in deposit insurance coverage levels between credit unions and banks Oppose additional Call Report fields on loans to credit union officials and senior executive staff Oppose additional Call Report fields on maturity distribution of uninsured shares Oppose making changes to Call Report requirements without using notice-and-comment process Oppose NCUA Call Report collection of overdraft and NSF fee revenue data Support modernization and simplification of Call Report form and instructions Support rescission of NCUA overdraft and NSF fee guidance Oppose collection of vendor information in NCUA Credit Union Profile Oppose changes to NCUA collection forms outside rulemaking process Support NCUA review of normal operating level and methodology Support NCUA action to permit credit union reimbursement of dependent care expenses for federal credit union official duties Oppose NCUA acting as a climate regulator Oppose NCUA rule on succession planning Oppose NCUA rule on record retention Oppose excessive NCUA requirements for supervisory committee audits Support NCUA action to reduce scope of supervisory committee examination Support NCUA recognition of digital banking in service facility definition Support clarification of NCUA member expulsion regulations Support NCUA proposed rule on increasing overdraft flexibility Support NCUA recognition of government sponsored enterprises as government agencies for loan maturity limit purposes Support NCUA adoption of floating interest rate cap Support modification of NCUA commercial loan definition Support increased flexibility in NCUA occupancy requirements Support NCUA action to clarify loan participation limits Support NCUA modification of low-income designation process Support expanding NCUA qualified charity definition Support allowing greater weighted average life for corporate credit unions financial assets Support extension of maturity limit for corporate credit union borrowing Support NCUA adopting limited retention period for operational records Support increased flexibility for advertising and notice of insured status Oppose proposed incentive-based compensation rule Support increased compliance timeline for NCUA simplification of share insurance rule Support removing reputational risk as a component of credit union examinations Support balanced implementation of debanking executive order Support increased NCUA efforts to promote credit union industry Support modernization and streamlining of NCUA operations Support NCUA supervisory flexibility for credit union shutdown assistance efforts Support NCUA action to modernize CAMELS rating system Support modernization of NCUA fidelity bond review requirements Support making CFPB subject to regular appropriations process Support increased CFPB budget transparency Support restructuring CFPB leadership to a bipartisan commission Support creation of a CFPB Inspector General Support reforms to CFPB Civil Investigative Demand process Support increasing asset thresholds for CFPB supervision of credit unions Support clarification of CFPB unfair, deceptive, or abusive acts and practices authority Support CFPB use of Section 1022 authority to exempt credit unions from certain regulations Support CFPB oversight and monitoring of nonbank entities Oppose CFPB efforts to avoid requirements of the rulemaking process Support CFPB use and disclosure of relevant data in rulemakings Support CFPB use of cost-benefit analysis in rulemaking process Support CFPB policies to promote innovation and access to credit Support CFPB coordination with NCUA on policy matters and examination scheduling Oppose mislabeling financial services fees as junk fees Oppose arbitrary limits on credit union fee income Oppose CFPB efforts to restrict information in credit reports Oppose CFPB efforts to manipulate consumer complaint data Support CFPB engaging in ongoing retrospective review of past regulations Support CFPB consumer complaint database reforms Support CFPB no-action letter program with extended timeline and increased protection of sensitive strategic information Oppose CFPB action to prohibit use of certain contractual terms and conditions Oppose expansion of consumer report and consumer reporting agency definitions under the Fair Credit Reporting Act/Regulation V Support consumer protection regulations for buy-now-pay-later loan providers Support inclusion of buy-now-pay-later loans in FHA underwriting Support CFPB use of Civil Penalty Fund for consumer financial education Support increase of Home Mortgage Disclosure Act reporting thresholds Support removal of disparate impact analysis from Regulation B and modification of discouragement standard Support credit union access to universal service fund letters of credit program Support recognition of unique credit union structure in Financial Data Transparency Act joint data standards Support federal data privacy and security standard that exempts Gramm-Leach-Bliley Act covered institutions, preempts state laws, operates on an opt-out basis, recognizes the complexity of data deletion, and does not authorize private right of action Support increased transparency for fintech bank charter applications Support Treasury development of model forms and qualified vehicle list for auto loan interest deduction Support safe harbor for credit unions related to the auto loan interest deduction Support clarification of remittance transfer tax exemptions Support inclusion of credit unions in Trump Accounts program Oppose development of a central bank digital currency Support credit union access to Federal Reserve liquidity options Support gradual expansion of Fedwire and National Settlement Service operating hours with optional participation Oppose addition of fourth same-day ACH window Support expanded flexibility for accessing the Fed discount window and intraday credit Oppose expanded eligibility for Federal Reserve master account access Oppose Regulation II debit interchange fee cap Oppose Federal Reserve proposed rule on modifying Regulation II debit interchange cap Support improvements to the Federal Reserves Debit Card Issuer Survey Oppose legislative action to impose caps or restrictions on debit or credit interchange fees Oppose legislative action to prohibit the Federal Reserve from paying interest on reserves Support Federal Reserve action to coordinate regulatory guidance on penny circulation issues and management of penny supply Support continued offering of Federal Reserve check services Oppose expansion of Electronic Fund Transfer Act/Regulation E financial institution liability Support fair distribution of Electronic Fund Transfer Act/Regulation E error resolution responsibilities Oppose Electronic Fund Transfer Act/Regulation E liability for financial institutions for consumer-authorized transactions Support clarification of funds definition under Electronic Fund Transfer Act/Regulation E Support clarification of Electronic Fund Transfer Act/Regulation E treatment of digital assets Support increased flexibility for check holds and funds availability requirements Support transition to electronic payments for government payments Support consumer education on transition to electronic payments Support clarification of information sharing safe harbor for identifying and preventing payments fraud Support greater flexibility for credit unions to decline services with clear indica of fraud or elder abuse Support parity for credit union provision of digital asset services Prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products Support Treasury and NCUA action to implement regulatory framework for stablecoin issuance Support parity for credit unions related to stablecoin regulation Support NCUAs role as primary regulator of credit unions stablecoin activities Oppose treating stablecoins or digital assets as federally insured Oppose payment of interest, yield, or rewards on stablecoin holdings Support digital assets guardrails to prevent deposit outflows Support clarifying credit unions authority to provide custodial services for their members Support safeguards for rehypothecation of digital assets Support reduced government-sponsored enterprises costs for credit union mortgages Support secondary mortgage market access for credit unions Support continued role for FHFA as an independent regulator Support credit union access to Federal Home Loan Bank system Support expansion of Federal Home Loan Bank Act community financial institution definition Support Federal Home Loan Bank engagement with credit unions Oppose adoption of volume-based incentives for Federal Home Loan Banks Oppose policy changes to limit access to Federal Home Loan Bank liquidity Support Federal Home Loan Bank allocations to the Affordable Housing Program Support FinCEN implementation of the Corporate Transparency Act Support additional time to implement anti-money laundering/countering financing of terrorism program changes and publication of guidance Support increasing Currency Transaction Report and Suspicious Activity Report filing thresholds Support streamlining Currency Transaction Report and Suspicious Activity Report forms Support increased inclusion of identifiable information in Section 314(a) information requests Support consistency between NCUA and FinCEN requirements on Bank Secrecy Act compliance Support FinCEN survey to accurately measure Bank Secrecy Act compliance costs Support DOD clarification of Military Lending Act and Servicemembers Civil Relief Act requirements Support standardized disclosures and financial literacy briefings for servicemembers Support credit union access to nominal leases on military installations Oppose nominal leases for banks on military installations Oppose legislative action on the Overseas Military Banking Program Oppose inclusion of interchange or interest rate cap amendments in the National Defense Authorization Act Support federal share insurance for all credit unions acting as fiscal agents of the U.S. government Support role of Community Development Financial Institutions Fund in promoting economic growth and access to capital in underserved communities Support access to Community Development Financial Institutions Fund awards and technical assistance for credit unions Support Community Development Financial Institutions Fund bond guarantee program Support Community Development Financial Institutions Fund liquidity enhancement pilot program Support disbursement of all Community Development Financial Institution Fund appropriated award funding Oppose additional barriers to disbursement of Community Development Financial Institution Fund appropriated award funding Support timely completion of Emergency Capital Investment Program disposition agreements Oppose CFPB rulemaking on contract terms and conditions Oppose reclassification of credit header information as a consumer report Oppose reliance on single source of documentation to determine instances of identity theft or coerced debt Oppose use of interim final rule to modify personal financial data rights requirements Support modification of Section 1033 rule to allow data providers to charge fees, remove prescriptive technology standards, and establish data privacy standards and allocation of liability Support increased reporting and small business revenue threshold and elimination of discretionary data points collection in revised Section 1071 rule Support modernization of e-signature requirements Support allowing electronic or documented oral credit card applications Support increased flexibility for disclosures Support rescission of CFPB payday lending rule payment provisions Support modification of FCC revocation of consent rule Support greater flexibility for FCC fraud alert exemption Support uniform federal standards and increased federal preemption of state laws on interchange, data privacy, artificial intelligence, and elder financial abuse reporting Issues related to housing finance reform Issues related to flood insurance Issues related to privately insured credit unions Issues related to credit union capital requirements Issues related to credit union conversions Issues related to credit unions as employers Issues related to the Foreign Account Tax Compliance Act Issues related to fair lending Issues related to the Telephone Consumer Protection Act Support Credit Union Board Modernization Act (H.R. 975; S. 522) Support 1071 Repeal to Protect Small Business Lending Act (H.R. 976; S. 557) Support Making the CFPB Accountable to Small Businesses Act (H.R. 1606) Support Financial Integrity and Regulation Management Act (S. 875; H.R. 2702; Senate Amendment 3104) Support Fair Audits and Inspections for Regulators Act (H.R. 940) Support Anti-CBDC Surveillance State Act (H.R. 1919; S. 1124) Support Veterans Member Business Loan Act (H.R. 507; S. 110; Senate Amendment 3776) Support Taking Account of Bureaucrats Spending Act (H.R. 654) Support Rectifying UDAAP Act (H.R. 1652) Support Civil Investigative Demand Reform Act (H.R. 1653) Support SECURE Notarization Act (H.R. 1777; S. 1561) Support Increasing Credit Union Lending for Business Growth Act (H.R. 1791) Support Financial Reporting Threshold Modernization Act (H.R. 1799; Amendment 715 to H.R. 3838) Support Home of Your Own Act (H.R. 2064) Support Homes for Every Local Protector, Educator, and Responder Act (H.R. 2094; S. 978) Support CFPB Dual Mandate and Economic Analysis Act (H.R. 2183) Support Transparency in CFPB Cost-Benefit Analysis Act (H.R. 2331) Support CFPB-IG Reform Act (H.R. 2513) Support Homebuyers Privacy Protection Act (H.R. 2808; S. 1467) Support Financial Institution Regulatory Tailoring Enhancement Act (H.R. 3230) Support Halting Uncertain Methods and Practices in Supervision Act (H.R. 3379) Support Taking Account of Institutions with Low Operation Risk Act (H.R. 3380) Support Bureau of Consumer Financial Protection Commission Act (H.R. 3445) Support Advancing the Mentor-Protege Program for Small Financial Institutions Act (H.R. 3709) Support Expanding Access to Lending Options Act (H.R. 4167) Support CDFI Bond Guarantee Program Improvement Act (S. 1880) Support Taskforce for Recognizing and Averting Payment Scams Act (H.R. 4936; S. 2019; Senate Amendment 3257) Support Capping Excessive Awarding of SBLC Entrants Act (H.R. 2987) Support Expanding Access to Lending Options Act (H.R. 4167) Support Supervisory Modifications for Appropriate Risk-Based Testing Act (H.R. 4437) Support Stop Agency Fiat Enforcement Act (H.R. 4460) Support American Access to Banking Act (H.R. 4544) Support Protecting Access to Credit for Small Businesses Act (S. 2486) Support Business of Insurance Regulatory Reform Act (H.R. 4735; S. 2419) Support NCUA Central Liquidity Facility Enhancement Act (S. 2545, S. 3575; Senate Amendments 3722, 3834, 4384) Support CDFI Fund Transparency Act (S. 2704; Senate Amendments 3640, 3732) Support Supporting Upgraded Property Projects and Lending for Yards Act (H.R. 4568) Support Unleashing AI Innovation in Financial Services Act (H.R. 4801) Support AI Practices, Logistics, Actions, and Necessities Act (H.R. 2152) Support Streamlining Transaction Reporting and Ensuring Anti-Money Laundering Improvements for a New Era Act (S. 3017) Support NFIP Continuation Act (H.R. 5577) Support Housing for the 21st Century Act (H.R. 6644) Support Regulatory Efficiency, Verification, Itemization, and Enhanced Workflow Act (H.R. 6544) Support Community Bank Regulatory Tailoring Act (H.R. 7056) Support Close the Shadow Banking Loophole Act (S. 3734) Support American Lending Fairness Act (S. 3889; H.R. 7866) Support Community Bank Relief Act (S. 3849; H.R. 7484) Support Access to Fair Financing for Opportunity and Resilient Development Act (Senate Amendments 4354, 4394; S. 3940) Support Growing Deposit Insurance for the Future Act (H.R. 8088) Support emergency transaction account guarantee legislation (H.R. 8075) Support inclusion of guidance on penny circulation in Common Cents Act (H.R. 3074) Support parity for credit unions and prohibition on stablecoin yield in Digital Asset Market Clarity Act (H.R. 3633) Support modification of Section 705 in Renewing Opportunity in the American Dream to Housing Act (S. 2651) Support inclusion of credit union parity provisions in Main Street Capital Access Act (H.R. 6955) Oppose 10 Percent Credit Card Interest Rate Cap Act (H.R. 1944; S. 381; Senate Amendment 2239) Oppose Credit Card Competition Act (Senate Amendments 2229, 2230, 2345, 4305; S. 3623; H.R. 7035) Oppose commissary interchange fee study (Senate Amendment 3216) Oppose End the Feds Big Bank Bailout Act (S. 2113; Senate Amendment 3761) Oppose Credit Card Fairness Act (S. 3660)

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

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

Met with the House and Senate on preemption issues Met with the House and Senate on issues impacting large global banks Met with the House and Senate on digital assets Met with the House and Senate on sanctions legislation Met with the House and Senate on market regulations Met with the House and Senate on bank capital regulations Met with the House and Senate on credit card pricing Met with the House and Senate on AML regulations Met with the House and Senate on geopolitical issues impacting the global economy, including China Met with the House and Senate on proposals related to outbound investment Met with the House and Senate on artificial intelligence Met with the House and Senate on fair access to banking issues and legislative proposals Met with the House and Senate on cybersecurity issues Met with the House and Senate on interchange issues/previously introduced Credit Card Competition Act Met with the House and Senate on bank supervision issues Met with the House and Senate on proposals related to deposit insurance Met with the House and Senate on proposals to revalue and demonetize U.S. gold reserves Draft legislation - Banking Regulator Accountability Act - all provisions H.R.2392, Stablecoin Transparency and Accountability for a Better Ledger Economy Act of 2025 - all provisions H.R.2548/S.1241, Sanctions Russia Act of 2025 - all provisions H.R.3655, Digital Market Clarity Act of 2025 - all provisions S.401/H.R.987, Fair Access to Banking Act - all provisions S.875/H.R.2702, Financial Integrity and Regulation Management (FIRM) Act - all provisions S.919/S.1582, Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act - all provisions S.1053/H.R.2246, Foreign Investment Guardrails to Help Thwart (FIGHT) China Act of 2025 - all provisions S.1582, GENIUS Act - all provisions S.2381/H.R.1944, the 10 Percent Credit Card Interest Rate Cap Act - all provisions S.2999, the Main Street Depositors Protection Act - all provisions

Client expense: $1,270,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

All legislation related to consumer lending regulation and consumer lending policy. Issues related to APR caps and de-risking. S. 875, The Financial Integrity and Regulation Management Act. H.R. 2702, The Financial Integrity and Regulation Management Act. S. 2781,Protecting Consumers from Unreasonable Credit Rates Act. S. 2326,Payment Choice Act of 2025. H.R. 1138,Payment Choice Act of 2025.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 145, Risk Disclosure and Investor Attestation Act H.R. 654, Taking Account of Bureaucrats Spending (TABS) Act of 2025 H.R. 1013/S. 424, Retirement Fairness for Charities and Educational Institutions Act of 2025 H.R. 1109, Litigation Transparency Act of 2025 H.R. 1190/S. 577, Expanding Access to Capital for Rural Job Creators Act H.R. 1827/S. 847, Child Care Availability and Affordability Act H.R. 1900, Bank Failure Prevention Act of 2025 H.R. 2225/S. 1808, Access to Small Business Investor Capital Act H.R. 2441/S. 1877, Improving Disclosure for Investors Act of 2025 H.R. 2675/S. 3180, Protecting Our Courts From Foreign Manipulation Act of 2025 H.R. 2702/S. 875, Financial Integrity and Regulation Management (FIRM) Act H.R. 3230, Financial Institution Regulatory Tailoring Enhancement Act H.R. 3301, ELEVATE Act of 2025 H.R. 3323, Helping Startups Continue to Grow Act H.R. 3339, Equal Opportunity for Investors Act of 2025 H.R. 3343, Greenlighting Growth Act of 2025 H.R. 3348, Accredited Investor Definition Review Act H.R. 3351, Improving Access to Small Business Information Act H.R. 3352, HALOS Act of 2025 H.R. 3357, Enhancing Multi-Class Share Disclosures Act H.R. 3379, HUMPS Act of 2025 H.R. 3380, TAILOR Act of 2025 H.R. 3381, Encouraging Public Offerings Act of 2025 H.R. 3382/S. 2924, Small Entity Update Act H.R. 3383, Increasing Investor Opportunities Act H.R. 3390, Bringing the Discount Window into the 21st Century Act H.R. 3394, Fair Investment Opportunities for Professional Experts Act H.R. 3395, Middle Market IPO Cost Act H.R. 3422, Promoting Opportunities for Non-Traditional Capital Formation Act H.R. 3446, The FDIC Board Accountability Act H.R. 3645, ACCESS Act of 2025 H.R. 3672, Securities Research Modernization Act H.R. 3673, Small Business Investor Capital Access Act H.R. 3682/S. 3578, Financial Stability Oversight Council Improvement Act of 2025 H.R. 3959, Protecting Private Job Creators Act H.R. 4429, Developing and Empowering Our Aspiring Leaders (DEAL) Act H.R. 4430, Expanding WKSI Eligibility Act H.R. 4431, Improving Capital Formation for Newcomers (ICAN) Act H.R. 4437, Supervisory Modifications for Appropriate Risk-based Testing (SMART) Act of 2025 H.R. 4478, Tailored Regulatory Updates for Supervisory Testing (TRUST) Act of 2025 H.R. 5291/S. 2663, Merchant Banking Modernization Act S. 985, PROTECT USA Act S. 1605, International Competition for American Jobs Act H.J.Res. 74/S.J.Res. 36, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to "Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information (Regulation V)" Potential legislation similar to H.R. 448, Putting Investors First Act Potential legislation similar to H.R. 2590, Unlocking Capital for Small Business Act of 2023 Potential legislation similar to H.R. 2607, Improving Crowdfunding Opportunities Act, 2023 Potential legislation similar to H.R. 2609, Small Entrepreneur Empowerment and Development Act of 2023 Potential legislation similar to H.R. 2622, to amend the Investment Advisers Act of 1940 to codify certain Securities and Exchange Commission no-action letters that exclude brokers and dealers compensated for certain research services from the definition of investment adviser Potential legislation similar to H.R. 2651, Regulation A+ Improvement Act of 2023 Potential legislation similar to H.R. 2790, the Improving Capital Allocation for Newcomers Act of 2021 Potential legislation similar to H.R. 2799, the Investment Opportunity Expansion Act, 2023 Potential legislation similar to H.R. 4168/S. 2005, Mandatory Materiality Act Potential legislation similar to H.R. 4767, Protecting Americans Retirement Savings from Politics Act Potential legislation similar to H.R. 5488/S. 2805, Protecting Our Courts from Foreign Manipulation Act of 2023 Potential legislation similar to H.R. 6623/S. 2068, Main Street Growth Act Potential legislation to repeal the SECs Universal Proxy Rule of 2021 Potential legislation to amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to repeal certain rulemaking requirements SEC Proposed Rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors (87 Fed. Reg. 21,334-21,473, April 11, 2022) Proposed Rule, Consumer Financial Protection Bureau; Protecting Americans from Harmful Data Broker Practices (Regulation V) (89 Fed. Reg. 101,402, December 13, 2024) Various issues relating to SEC Best Interest and Enhancing Investment Adviser Regulation relating to broker-dealers, registered investment advisers, conflicts of interest; potential federal preemption of state fiduciary standards; CFTCs de minimis Exception for Swap Dealers; Securities and Exchange Commission amendments to the Commissioners whistleblower rules file no. S7-16-18; proxy process, proxy advisory firms, and other related aspects of corporate governance; corporate common ownership; adoption of the current expected credit loss (CECL) accounting standard; role of credit reporting agencies (CRAs) in the U.S. economy; debt collection practices (regulation F) under the Fair Debt Collection Practices Act (P.L. 95-109); qualified mortgage definition under the Truth in Lending Act (P.L. 90-321) (Regulation Z); Financial Stability Oversight Council activities, including the approach to and designation of systemic importance and risk of nonbank financial companies and firms; Federal Reserve Systems Large Institution Supervision Coordinating Committee; potential housing finance reform legislation; enforcement of Securities and Exchange Commission penalties; federal interest rate authority; Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) reform; electronic consent-based SSN Verification Service (eCBSV); environmental, social, and governance (ESG) enforcement; information collection under the Community Reinvestment Act (CRA) (P.L. 95-128); potential Financial Transaction Tax (FTT); potential Treasury Department proposal relating to tax reporting by banks; investment company cross trading; potential money market fund reform measures; transition to the secured overnight financing rate; implementation of SEC Rule 15c2-11; Department of Labor fiduciary advice exemption: PTE 2020-02; modernization of the Credit Repair Organizations Act (enacted as Title IV of the Consumer Credit Protection Act, P.L. 90-321); Internal Revenue Service Priority Guidance Plan; Financial Accounting Standards Board improvements to income tax disclosures; Climate-Related Financial Risk Management for Large Banks; Consumer Financial Protection Bureau (CFPB) regulatory sandbox for disclosures; CFPB Policy Fellowship program; CFPB amendment of its Supervision and Examination Manual; CFPB conflation of Distinct Statutory Concepts of Unfairness and Discrimination; CFPB Small Business Advisory Review Panels Rulemaking on Personal Financial Data Rights; CFPB implementation of the Small Business Lending Data Collection Rule (the 1071 Rule); SEC Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting (File Number S7-26-22); Federal Deposit Insurance Corporation Proposal on Corporate Governance and Risk Management; Basel III Endgame Rule; FDIC Monitoring of Investment Funds Passivity Agreements; issues related to the Export-Import Bank of the United States; European Unions (EU) Corporate Sustainability Due Diligence Directive (CSDDD); Consumer Financial Protection Circular 2024-05, Improper Overdraft Opt-In Practices; Executive Order 14036, Promoting Competition in the American Economy; recommendations for Securities and Exchange Commission regulatory agenda; reforming SEC Rule 14a-8; FSOC restoration of 2019 Guidance governing the designation of nonbank financial institutions; reauthorization of the U.S. International Development Finance Corporation; implementation of the One Big Beautiful Bill Act, (P.L. 119-21); implementation of Disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Overdraft Lending: Very Large Financial Institutions" (P.L. No: 119-10); implementation of A joint resolution disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications" (P.L. 119-11); proxy process and shareholder proposal system overseen by SEC; FSOC Nonbank Guidance - request to restore the 2019 Guidance (July 14, 2025, letter to Treasury); reporting metrics of American companies under the EUs Corporate Sustainability Reporting Directive and Corporate Sustainability Due Diligence Directive; index fund passivity; reform to the function of the Public Company Accounting Oversight Board; rulemaking regarding corporate exemptions for shareholder proposals under SEC Rule 14a-8; rulemaking regarding reform to the proxy voting advice industry at the SEC; request for comment from SEC on potential revisions to executive compensation disclosure; request for comment from SEC on potential revisions to definition of Foreign Private Issuer; SEC Compliance and Disclosure Interpretations: Regulation 13D-G (February 11, 2025); potential policy affirming materiality as the standard for corporate disclosure at the SEC; Executive Order 14366, Protecting American Investors from Foreign-Owned and Politically-Motivated Proxy Advisors; Executive Order 14330, Democratizing Access to Alternative Assets for 401(K) Investors; SEC Staff Review ADI 2025-16 on Registered Closed-End Funds of Private Funds (August 15, 2025); acquired fund fees and expenses mandate under Rule 12d1-4 (impact of AFFE on BDCs and inclusion of alternative assets in 401(K)s); potential policy from SEC on electronic delivery of investor disclosure information; oversight issues and potential legislation on third party litigation funding, including its national security implications

Client expense: $17,960,000 · Firm income: Not reported

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

H.R. 654, TABS Act of 2025 H.R. 940, Fair Audits and Inspections for Regulators (FAIR) Exams Act H.R. 1602, Financial Privacy Act of 2025 H.R. 1900, Bank Failure Prevention Act of 2025 H.R. 2702/S. 875, Financial Integrity and Regulation Management (FIRM) Act H.R. 3230, Financial Institution Regulatory Tailoring Enhancement Act H.R. 3379, Halting Uncertain Methods and Practices in Supervision Act of 2025 H.R. 3380, Taking Account of Institutions with Low Operation Risk (TAILOR) Act of 2025 H.R. 3390, Bringing the Discount Window into the 21st Century Act H.R. 3446, FDIC Board Accountability Act H.R. 4437, Supervisory Modifications for Appropriate Risk-based Testing (SMART) Act of 2025 H.R. 4478, Tailored Regulatory Updates for Supervisory Stress Testing (TRUST) Act of 2025 H.R. 5270, Stress Testing Accountability and Transparency Act H.R. 5291/S. 2663, Merchant Banking Modernization Act H.J.Res. 59/S.J.Res. 18, Disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Overdraft Lending: Very Large Financial Institutions" H.J.Res. 64/S.J.Res. 28, Disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications" H.J. Res.74/S.J. Res.36, Disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information (Regulation V)" Draft legislation to amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to repeal certain rulemaking requirements Potential legislation regarding the funding of the Consumer Financial Protection Bureau Proposed Rule, Consumer Financial Protection Bureau; Overdraft Lending: Very Large Financial Institutions (89 Fed. Reg. 13,852-13,908, February 23, 2024) Proposed Rule, Federal Deposit Insurance Corporation, Statement of Policy on Bank Merger Transactions (89 Fed. Reg. 29,222-29,244, June 18, 2024) Proposed Rule, Consumer Financial Protection Bureau: Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information (Regulation V) (89 Fed. Reg. 51,682-51,736, June 18, 2024) Proposed Rule, Consumer Financial Protection Bureau; Protecting Americans from Harmful Data Broker Practices (Regulation V) (88 Fed. Reg. 101,402-101,462, December 13, 2024) Advance Notice of Proposed Rulemaking, Consumer Financial Protection Bureau; Fair Credit Reporting Act (Regulation V); Identity Theft and Coerced Debt (89 Fed. Reg. 100,922-100,923, December 13, 2024) Final Rule, Consumer Financial Protection Bureau; Credit Card Penalty Fees (Regulation Z) (89 Fed. Reg. 19,128-19,223, March 15, 2024) Proposed Rule, Consumer Financial Protection Bureau; Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications (88 Fed. Reg. 80,197-80,216, November 17, 2023) Proposed Rule, Federal Reserve Board: Modifications to the Capital Plan Rule and Stress Capital Buffer Requirement (90 Fed. Reg. 16,843-16,860, April 22, 2025) Proposed Rule, Office of the Comptroller of the Currency, Treasury; the Board of Governors of the Federal Reserve System; and the Federal Deposit Insurance Corporation: Modifications to the Enhanced Supplementary Leverage Ratio Standards for U.S. Global Systemically Important Bank Holding Companies and Their Subsidiary Depository Institutions; Total Loss-Absorbing Capacity and Long-Term Debt Requirements for U.S. Global Systemically Important Bank Holding Companies (90 Fed. Reg. 30,780-30,817, July 10, 2025) Proposed rule, Consumer Financial Protection Bureau; Equal Credit Opportunity Act (Regulation B) (90 Fed. Reg. 50,901-50,923, October 13, 2025) Various issues relating to Regulatory Capital Rules: Regulatory Capital, Implementation of Basel III, Capital Adequacy, Transition Provisions, Prompt Corrective Action, Standardized Approach for Risk-weighted Assets, Market Discipline and Disclosure Requirements, Advanced Approaches Risk-Based Capital Rule, and Market Risk Capital Rule; potential rulemaking regarding Section 956 of the Dodd-Frank Act (P.L. 111-203); independent monetary policy by the Federal Reserve System

Client expense: $17,960,000 · Firm income: Not reported

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

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

Client expense: $1,700,000 · 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 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)

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

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

All legislation related to consumer lending regulation and consumer lending policy. Issues related to APR caps and de-risking. S. 875, The Financial Integrity and Regulation Management Act. H.R. 2702, The Financial Integrity and Regulation Management Act. S. 2781,Protecting Consumers from Unreasonable Credit Rates Act. S. 2326,Payment Choice Act of 2025. H.R. 1138,Payment Choice Act of 2025.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Met with the House and Senate on preemption issues Met with the House and Senate on issues impacting large global banks Met with the House and Senate on digital assets Met with the House and Senate on sanctions legislation Met with the House and Senate on market regulations Met with the House and Senate on bank capital regulations Met with the House and Senate on credit card pricing Met with the House and Senate on AML regulations Met with the House and Senate on geopolitical issues impacting the global economy, including China Met with the House and Senate on proposals related to outbound investment Met with the House and Senate on artificial intelligence Met with the House and Senate on fair access to banking issues and legislative proposals Met with the House and Senate on cybersecurity issues Met with the House and Senate on interchange issues/previously introduced Credit Card Competition Act Met with the House and Senate on bank supervision issues Met with the House and Senate on proposals related to deposit insurance Draft legislation - Banking Regulator Accountability Act - all provisions H.R.2392, Stablecoin Transparency and Accountability for a Better Ledger Economy Act of 2025 - all provisions H.R.2548/S.1241, Sanctions Russia Act of 2025 - all provisions H.R.3655, Digital Market Clarity Act of 2025 - all provisions S.401/H.R.987, Fair Access to Banking Act - all provisions S.875/H.R.2702, Financial Integrity and Regulation Management (FIRM) Act - all provisions S.919/S.1582, Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act - all provisions S.1053/H.R.2246, Foreign Investment Guardrails to Help Thwart (FIGHT) China Act of 2025 - all provisions S.1582, GENIUS Act - all provisions S.2381/H.R.1944, the 10 Percent Credit Card Interest Rate Cap Act - all provisions S.2999, the Main Street Depositors Protection Act - all provisions

Client expense: $1,420,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 145, Risk Disclosure and Investor Attestation Act H.R. 654, Taking Account of Bureaucrats Spending (TABS) Act of 2025 H.R. 1013/S. 424, Retirement Fairness for Charities and Educational Institutions Act of 2025 H.R. 1109, Litigation Transparency Act of 2025 H.R. 1190/S. 577, Expanding Access to Capital for Rural Job Creators Act H.R. 1827/S. 847, Child Care Availability and Affordability Act H.R. 1900, Bank Failure Prevention Act of 2025 H.R. 2225/S. 1808, Access to Small Business Investor Capital Act H.R. 2441/S. 1877, the Improving Disclosure for Investors Act of 2025 H.R. 2675, Protecting Our Courts From Foreign Manipulation Act of 2025 H.R. 2702/S. 875, Financial Integrity and Regulation Management (FIRM) Act H.R. 3230, Financial Institution Regulatory Tailoring Enhancement Act H.R. 3301, ELEVATE Act of 2025 H.R. 3323, Helping Startups Continue to Grow Act H.R. 3339, Equal Opportunity for Investors Act of 2025 H.R. 3343, Greenlighting Growth Act of 2025 H.R. 3348, Accredited Investor Definition Review Act H.R. 3351, Improving Access to Small Business Information Act H.R. 3352, HALOS Act of 2025 H.R. 3357, Enhancing Multi-Class Share Disclosures Act H.R. 3379, HUMPS Act of 2025 H.R. 3380, TAILOR Act of 2025 H.R. 3381, Encouraging Public Offerings Act of 2025 H.R. 3382, Small Entity Update Act H.R. 3383, Increasing Investor Opportunities Act H.R. 3390, Bringing the Discount Window into the 21st Century Act H.R. 3394, Fair Investment Opportunities for Professional Experts Act H.R. 3395, Middle Market IPO Cost Act H.R. 3422, Promoting Opportunities for Non-Traditional Capital Formation Act H.R. 3446, The FDIC Board Accountability Act H.R. 3645, ACCESS Act of 2025 H.R. 3672, Securities Research Modernization Act H.R. 3673, Small Business Investor Capital Access Act H.R. 3682, Financial Stability Oversight Council Improvement Act of 2025 H.R. 3959, Protecting Private Job Creators Act H.R. 4429, Developing and Empowering Our Aspiring Leaders (DEAL) Act H.R. 4430, Expanding WKSI Eligibility Act H.R. 4431, Improving Capital Formation for Newcomers (ICAN) Act H.R. 4429, Developing and Empowering Our Aspiring Leaders (DEAL) Act H.R. 4437, Supervisory Modifications for Appropriate Risk-based Testing (SMART) Act of 2025 H.R. 4478, Tailored Regulatory Updates for Supervisory Testing (TRUST) Act of 2025 H.R. 5291/S. 2663, Merchant Banking Modernization Act S. 985, PROTECT USA Act S. 1605, International Competition for American Jobs Act H.J. Res. 74/S.J. Res. 36, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to "Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information (Regulation V)" Potential legislation similar to H.R. 448, Putting Investors First Act Potential legislation similar to H.R. 2590, Unlocking Capital for Small Business Act of 2023 Potential legislation similar to H.R. 2607, Improving Crowdfunding Opportunities Act, 2023 Potential legislation similar to H.R. 2609, Small Entrepreneur Empowerment and Development Act of 2023 Potential legislation similar to H.R. 2622, to amend the Investment Advisers Act of 1940 to codify certain Securities and Exchange Commission no-action letters that exclude brokers and dealers compensated for certain research services from the definition of investment adviser Potential legislation similar to H.R. 2651, Regulation A+ Improvement Act of 2023 Potential legislation similar to H.R. 2790, the Improving Capital Allocation for Newcomers Act of 2021 Potential legislation similar to H.R. 2799, the Investment Opportunity Expansion Act, 2023 Potential legislation similar to H.R. 4168/S. 2005, Mandatory Materiality Act Potential legislation similar to H.R. 5488/S. 2805, Protecting Our Courts from Foreign Manipulation Act of 2023 Potential legislation similar to H.R. 6623/S. 2068, Main Street Growth Act Potential legislation to repeal the SECs Universal Proxy Rule of 2021 Potential legislation to amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to repeal certain rulemaking requirements SEC Proposed Rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors (87 Fed. Reg. 21,334-21,473, April 11, 2022) Proposed Rule, Consumer Financial Protection Bureau; Protecting Americans from Harmful Data Broker Practices (Regulation V) (89 Fed. Reg. 101,402, December 13, 2024) Various issues relating to SEC Best Interest and Enhancing Investment Adviser Regulation relating to broker-dealers, registered investment advisers, conflicts of interest; potential federal preemption of state fiduciary standards; CFTCs de minimis Exception for Swap Dealers; Securities and Exchange Commission amendments to the Commissioners whistleblower rules file no. S7-16-18; proxy process, proxy advisory firms, and other related aspects of corporate governance; corporate common ownership; adoption of the current expected credit loss (CECL) accounting standard; role of credit reporting agencies (CRAs) in the U.S. economy; debt collection practices (regulation F) under the Fair Debt Collection Practices Act (P.L. 95-109); qualified mortgage definition under the Truth in Lending Act (P.L. 90-321) (Regulation Z); Financial Stability Oversight Council activities, including the approach to and designation of systemic importance and risk of nonbank financial companies and firms; Federal Reserve Systems Large Institution Supervision Coordinating Committee; potential housing finance reform legislation; enforcement of Securities and Exchange Commission penalties; federal interest rate authority; Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) reform; electronic consent-based SSN Verification Service (eCBSV); environmental, social, and governance (ESG) enforcement; information collection under the Community Reinvestment Act (CRA) (P.L. 95-128); potential Financial Transaction Tax (FTT); potential Treasury Department proposal relating to tax reporting by banks; investment company cross trading; potential money market fund reform measures; transition to the secured overnight financing rate; implementation of SEC Rule 15c2-11; Department of Labor fiduciary advice exemption: PTE 2020-02; modernization of the Credit Repair Organizations Act (enacted as Title IV of the Consumer Credit Protection Act, P.L. 90-321); Internal Revenue Service Priority Guidance Plan; Financial Accounting Standards Board improvements to income tax disclosures; Climate-Related Financial Risk Management for Large Banks; Consumer Financial Protection Bureau (CFPB) regulatory sandbox for disclosures; CFPB Policy Fellowship program; CFPB amendment of its Supervision and Examination Manual; CFPB conflation of Distinct Statutory Concepts of Unfairness and Discrimination; CFPB Small Business Advisory Review Panels Rulemaking on Personal Financial Data Rights; CFPB implementation of the Small Business Lending Data Collection Rule (the 1071 Rule); SEC Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting (File Number S7-26-22); Federal Deposit Insurance Corporation Proposal on Corporate Governance and Risk Management; Basel III Endgame Rule; FDIC Monitoring of Investment Funds Passivity Agreements; issues related to the Export-Import Bank of the United States; European Unions (EU) Corporate Sustainability Due Diligence Directive (CSDDD); Consumer Financial Protection Circular 2024-05, Improper Overdraft Opt-In Practices; Executive Order 14036, Promoting Competition in the American Economy; recommendations for Securities and Exchange Commission regulatory agenda; Reforming SEC Rule 14a-8; FSOC restoration of 2019 Guidance governing the designation of nonbank financial institutions; reauthorization of the U.S. International Development Finance Corporation; implementation of the One Big Beautiful Bill Act, (P.L. 119-21); implementation of Disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Overdraft Lending: Very Large Financial Institutions" (P.L. No: 119-10); implementation of a joint resolution disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications" (P.L. No: 119-11); proxy process and shareholder proposal system overseen by SEC; FSOC Nonbank Guidance - request to restore the 2019 Guidance (July 14, 2025, letter to Treasury); reporting metrics of American companies under the EUs Corporate Sustainability Reporting Directive and Corporate Sustainability Due Diligence Directive; index fund passivity; reform to the function of the Public Company Accounting Oversight Board; rulemaking regarding corporate exemptions for shareholder proposals under SEC Rule 14a-8; rulemaking regarding reform to the proxy voting advice industry at the SEC; request for comment from SEC on potential revisions to executive compensation disclosure; request for comment from SEC on potential revisions to definition of Foreign Private Issuer; SEC Compliance and Disclosure Interpretations: Regulation 13D-G (February 11, 2025); potential policy affirming materiality as the standard for corporate disclosure at the SEC; Executive Order 14330, Democratizing Access to Alternative Assets for 401(K) Investors; SEC Staff Review ADI 2025-16 on Registered Closed-End Funds of Private Funds (August 15, 2025); acquired fund fees and expenses mandate under Rule 12d1-4 (impact of AFFE on BDCs and inclusion of alternative assets in 401(K)s); oversight issues and potential legislation on third party litigation funding, including its national security implications

Client expense: $13,650,000 · Firm income: Not reported

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

H.R. 654, TABS Act of 2025 H.R. 940, Fair Audits and Inspections for Regulators (FAIR) Exams Act H.R. 1602, Financial Privacy Act of 2025 H.R. 1900, Bank Failure Prevention Act of 2025 H.R. 2702/S. 875, Financial Integrity and Regulation Management (FIRM) Act H.R. 3230, Financial Institution Regulatory Tailoring Enhancement Act H.R. 3379, Halting Uncertain Methods and Practices in Supervision Act of 2025 H.R. 3380, Taking Account of Institutions with Low Operation Risk (TAILOR) Act of 2025 H.R. 3390, the Bringing the Discount Window into the 21st Century Act H.R. 3446, the FDIC Board Accountability Act H.R. 4437, the Supervisory Modifications for Appropriate Risk-based Testing (SMART) Act of 2025 H.R. 4478, the Tailored Regulatory Updates for Supervisory Stress Testing (TRUST) Act of 2025 H.R. 5270, the Stress Testing Accountability and Transparency Act H.R. 5291/S.2663, Merchant Banking Modernization Act H.J. Res. 59/S.J. Res. 18, Disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Overdraft Lending: Very Large Financial Institutions" H.J. Res. 64/S.J. Res. 28, Disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications" H.J. Res. 74/S.J. Res. 36, Disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information (Regulation V)" Draft legislation titled To amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to repeal certain rulemaking requirements Potential legislation regarding the funding of the Consumer Financial Protection Bureau Proposed Rule, Consumer Financial Protection Bureau; Overdraft Lending: Very Large Financial Institutions (89 Fed. Reg. 13,852-13,908, February 23, 2024) Proposed Rule, Federal Deposit Insurance Corporation, Statement of Policy on Bank Merger Transactions (89 Fed. Reg. 29,222-29,244, June 18, 2024) Proposed Rule, Consumer Financial Protection Bureau: Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information (Regulation V) (89 Fed. Reg. 51,682-51,736, June 18, 2024) Proposed Rule, Federal Deposit Insurance Corporation; Regulations Implementing the Change in Bank Control Act (89 Fed. Reg. 67,002-67,009, August 19, 2024) Proposed Rule, Federal Deposit Insurance Corporation: Unsafe and Unsound Banking Practices: Brokered Deposits Restrictions (89 Fed. Reg. 68,244-68,272, August 23, 2024) Proposed Rule, Consumer Financial Protection Bureau; Protecting Americans from Harmful Data Broker Practices (Regulation V) (88 Fed. Reg. 101,402-101,462, December 13, 2024) Advance Notice of Proposed Rulemaking, Consumer Financial Protection Bureau; Fair Credit Reporting Act (Regulation V); Identity Theft and Coerced Debt (89 Fed. Reg. 100,922-100,923, December 13, 2024) Final Rule, Consumer Financial Protection Bureau; Credit Card Penalty Fees (Regulation Z) (89 Fed. Reg. 19,128-19,223, March 15, 2024) Proposed Rule, Consumer Financial Protection Bureau; Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications (88 Fed. Reg. 80,197-80,216, November 17, 2023) Proposed Rule, Federal Reserve Board: Modifications to the Capital Plan Rule and Stress Capital Buffer Requirement (90 Fed. Reg. 16,843-16,860, April 22, 2025) Proposed Rule, Office of the Comptroller of the Currency, Treasury; the Board of Governors of the Federal Reserve System; and the Federal Deposit Insurance Corporation: Modifications to the Enhanced Supplementary Leverage Ratio Standards for U.S. Global Systemically Important Bank Holding Companies and Their Subsidiary Depository Institutions; Total Loss-Absorbing Capacity and Long-Term Debt Requirements for U.S. Global Systemically Important Bank Holding Companies (90 Fed. Reg. 30,780-30,817, July 10, 2025) Various issues relating to Regulatory Capital Rules: Regulatory Capital, Implementation of Basel III, Capital Adequacy, Transition Provisions, Prompt Corrective Action, Standardized Approach for Risk-weighted Assets, Market Discipline and Disclosure Requirements, Advanced Approaches Risk-Based Capital Rule, and Market Risk Capital Rule; potential rulemaking regarding Section 956 of the Dodd-Frank Act (P.L. 111-203); independent monetary policy by the Federal Reserve System

Client expense: $13,650,000 · Firm income: Not reported

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

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

Client expense: $2,170,000 · Firm income: Not reported

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

Opposing the funding contingency plans for the CFPB and CFDI Fund CFPB authority and funtions, related to structure and supervision, research and enforcement priorities; Supervision and enforcement of unregulated "fintech" products and non-brank lenders; Ongoing concerns with other office closures and RIFs at CFPB, Treasury and CDFI Lending Fund; Ongoing concerns with administration efforts to eliminate or consolidate prudential regulators of banking services; H.R. 654, opposing the Taking Account of Bureaucrats Spending (TABS) Act of 2025; H.R. 2392, opposing the Stablecoin Transparency and Accountability for a Better Ledger Economy (STABLE) Act of 2025; H.R. 3633, opposing the Digital Asset Market Clarity Act (CLARITY Act) of 2025; H.R. 2702 / S. 875, opposing the Financial Integrity and Regulation Management Act (FIRM Act); H.R. 4544, supporting the American Access to Banking Act, a bill to promote the formation of de novo regulated institutions; S.1582, opposing the GENIUS Act - a bill establishing a regulatory framework for payment stablecoins; H.R. 2885, opposing the Bank Loan Privacy Act H.R. 1606, opposing the Making the CFPB Accountable to Small Business Act H.R. 2331, oppposing the Transparency in CFPB Cost-Benefit Analysis Act H.R. 2183, opposing the CFPB Dual Mandate and Economic Analysis Act H.R. 3445, opposing the Commission of the Bureau of Consumer Financial Protection Act 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 the Earned Wage Access Consumer Protection Act H.R. ____, opposing the Small Dollar Loan Certainty Act S. 2429, supporting the Stop the Scammers Act

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

Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of

S. 401, H.R. 2702, S. 2651- Discussed bank regulatory policy. Discussed home mortgage loan originations, servicing and refinancing, and related issues.

Client expense: $1,140,000 · Firm income: Not reported

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

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)

Client expense: $1,070,000 · Firm income: Not reported

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

Credit Card Competition Act H.R.2702 FIRM Act H.R. 940, the Fair Audits and Inspections for Regulators (FAIR) Exams Act H.R. 1900, the Bank Failure Prevention Act of 2025 H.R. 3230, the Financial Institution Regulatory Tailoring Enhancement 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" Bank capital rules Crypto Regulatory Legislation Big Tech Crypto/Blockchain investments digital assets regulation Central Bank Digital Currency Crypto Broker Tax Reporting Guidance Digital assets regulation (stablecoins; banking standards for crypto) H.R. 2392 STABLE Act (stablecoins) S. 1582 GENIUS Act (stablecoins) S. 710 Crypto ATM Fraud Prevention Act H. R. 1919 Anti-CBDC Surveillance State Act H.R. 3633, the CLARITY Act (crypto market regulation) Crypto and Government Ethics, Dislcosure, Constitutional issues PE and childcare Climate/economic research

Client expense: $150,000 · Firm income: Not reported

Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE

H.R. 1 One Big Beautiful Bill Act Credit Card Competition Act H.R.2702 FIRM Act H.R. 940, the Fair Audits and Inspections for Regulators (FAIR) Exams Act H.R. 1900, the Bank Failure Prevention Act of 2025 H.R. 3230, the Financial Institution Regulatory Tailoring Enhancement 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" Bank capital rules PCAOB Office of Financial Research H.R. 2225 Access to Small Business Investor Act H.R. 3352 Helping Angels Lead Our Startups (HALOS) Act of 2025 H.R. 3301, a bill to amend the Securities Exchange Act of 1934 to specify certain registration statement contents for emerging growth companies, to permit issuers to file draft registration statements with the Securities and Exchange Commission for confidential review H.R. 3394, the Fair Investment Opportunities for Professional Experts Act H.R. 3381, the Encouraging Public Offerings Act of 2025 H.R. 3716 the Systemic Risk Authority Transparency Act H.R. 3672, the Securities Research Modification Act H.R. 3645, the Amendment for Crowdfunding Capital Enhancement and Small-business Support (ACCESS) Act H.R. 2835, the Small Bank Holding Company Relief Act H.R. 3323, Helping Startups Continue to Grow Act H.R. 3343, the Greenlighting Growth Act H.R. 3339, the Equal Opportunity for All Investors Act of 2025 H.R. 3348, the Accredited Investor Definition Review Act H.R. 2441, the Improving Disclosure for Investors Act of 2025 "H.R. 1013, the Retirement Fairness for Charities and Educational Institutions Act of 2025" H.R. 3383, the Increasing Investor Opportunities Act H.R. 1469, the Senior Security Act of 2025 H.R. 3357, the Enhancing Multi-Class Share Disclosures Act H.R. 3395, the Middle Market IPO Underwriting Cost Act "H.R. 3422, the Promoting Opportunities for Non-Traditional Capital Formation Act" private equity regulation private equity in health care Crypto Regulatory Legislation Big Tech Crypto/Blockchain investments digital assets regulation Central Bank Digital Currency Crypto Broker Tax Reporting Guidance Digital assets regulation (stablecoins; banking standards for crypto) H.R. 2392 STABLE Act (stablecoins) S. 1582 GENIUS Act (stablecoins) S. 710 Crypto ATM Fraud Prevention Act H. R. 1919 Anti-CBDC Surveillance State Act H.R. 3633, the CLARITY Act (crypto market regulation) H.R. 3573, Stop TRUMP in Crypto Act of 2025 H.R. 1712 Modern Emoluments and Malfeasance "Meme" Act "H.R.2982, the Fair Taxation of Digital Assets in Puerto Rico Act" Crypto and Government Ethics, Dislcosure, Constitutional issues PE and childcare H.R. 2988, Protecting Prudent Investment of Retirement Savings Act (lobbied against) "H.R. 3140, Stop Subsidizing Multimillion Dollar Corporate Bonuses Act" Insurance crisis consumer protections, supervision, and bailout policy NFIP policy discussion

Client expense: $150,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R.1, One Big Beautiful Bill Act, provisions relating to Medicaid and CHIP funding for gender procedures and surgeries; federal payments to large abortion providers; health care cost-sharing reduction payments; essential health benefits; tax credits for contributions to scholarship granting organizations; child tax credit; earned income tax credit; litigation funding; restriction on enforcement; artificial intelligence under the broadband equity, access, and deployment program; ineligibility based on low earning outcomes; and unrelated business taxable income. S.1821, Tackling Predatory Litigation Funding Act, amending the Internal Revenue Code of 1986 to establish a tax on income from litigation which is received by third-party entities that provided financing for such litigation, all provisions. S.1582, GENIUS Act, providing for the regulation of payment stablecoins, all provisions. S.875/H.R.2702, FIRM Act, curtailing the political weaponization of Federal banking agencies by eliminating reputational risk as a component of the supervision of depository institutions, all provisions. Issues relating to debanking; access to capital and capital markets; bolstering protections for fair access; improving litigators' ability to hold regulators accountable; and empowering certain state regulation.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE, White House Office

Issues related to capital and liquidity standards Issues related to risk-based capital requirements Issues related to leverage capital requirements Issues related to the capital surcharge for global systemically important banks Issues related to Basel III finalization Issues related to the regulation of nonbanks Issues related to the Federal Reserves stress testing regime Issues related to the supervision of large banks Issues related to payment stablecoins and issuers Issues related to digital asset market structure Issues related to bank intermediation of digital assets Issues related to the provision of bank services S.394: Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act of 2025 H.R.2392: Stablecoin Transparency and Accountability for a Better Ledger Economy (STABLE) Act of 2025 H.R. 3633: Digital Asset Market Clarity (CLARITY) Act S.875/H.R. 2702: Financial Integrity and Regulation Management (FIRM) Act H.R.940: Fair Audits and Inspections for Regulators Exams (FAIR Exams) Act

Client expense: $710,000 · Firm income: Not reported

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

H.R. 1, One Big Beautiful Bill Act H.R. 145, Risk Disclosure and Investor Attestation Act H.R. 654, Taking Account of Bureaucrats Spending (TABS) Act of 2025 H.R. 1013, Retirement Fairness for Charities and Educational Institutions Act of 2025 H.R. 1109, Litigation Transparency Act of 2025 H.R. 1190, Expanding Access to Capital for Rural Job Creators Act H.R. 1827/S. 847, Child Care Availability and Affordability Act H.R. 1900, Bank Failure Prevention Act of 2025 H.R. 2225, Access to Small Business Investor Capital Act H.R. 2441/S. 1877, the Improving Disclosures for Investors Act of 2025 H.R. 2675 Protecting Our Courts From Foreign Manipulation Act of 2025 H.R. 2702/S. 875, Financial Integrity and Regulation Management (FIRM) Act H.R. 3230, Financial Institution Regulatory Tailoring Enhancement Act H.R. 3301, ELEVATE Act of 2025 H.R. 3323, Helping Startups Continue to Grow Act H.R. 3339, Equal Opportunity for Investors Act of 2025 H.R. 3343, Greenlighting Growth Act of 2025 H.R. 3348, Accredited Investor Definition Review Act H.R. 3351, Improving Access to Small Business Information Act H.R. 3352, HALOS Act of 2025 H.R. 3357, Enhancing Multi-Class Share Disclosures Act H.R. 3379, HUMPS Act of 2025 H.R. 3380, TAILOR Act of 2025 H.R. 3381, Encouraging Public Offerings Act of 2025 H.R. 3382, Small Entity Update Act H.R. 3383, Increasing Investor Opportunities Act H.R. 3394, Fair Investment Opportunities for Professional Experts Act H.R. 3395, Middle Market IPO Underwriting Cost Act H.R. 3422, Promoting Opportunities for Non-Traditional Capital Formation Act H.R. 3645, ACCESS Act of 2025 H.R. 3672, Securities Research Modernization Act H.R. 3673, Small Business Investor Capital Access Act H.R. 3682, Financial Stability Oversight Council Improvement Act of 2025 H.R. 3959, Protecting Private Job Creators Act S. 985, PROTECT USA Act S. 1605, International Competition for American Jobs Act H.J.Res. 59/S.J.Res. 18, Disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Overdraft Lending: Very Large Financial Institutions" S.J.Res. 28, A joint resolution disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications" Potential legislation to use the Congressional Review Act to overturn a Consumer Financial Protection Bureau (CFPB) rule that removes medical debt from credit reports Potential legislation similar to H.R. 448, Putting Investors First Act Potential legislation similar to H.R. 2025/S. 840, Litigation Funding Transparency Act Potential legislation similar to H.R. 2579, the Developing and Empowering our Aspiring Leaders Act of 2023 Potential legislation similar to H.R. 2590, Unlocking Capital for Small Business Act of 2023 Potential legislation similar to H.R. 2607, Improving Crowdfunding Opportunities Act, 2023 Potential legislation similar to H.R. 2609, Small Entrepreneur Empowerment and Development Act of 2023 Potential legislation similar to H.R. 2651, Regulation A+ Improvement Act of 2023 Potential legislation similar to H.R. 2622, to amend the Investment Advisers Act of 1940 to codify certain Securities and Exchange Commission no-action letters that exclude brokers and dealers compensated for certain research services from the definition of investment adviser Potential legislation similar to H.R. 2799, the Investment Opportunity Expansion Act, 2023 Potential legislation similar to H.R. 2790, the Improving Capital Allocation for Newcomers Act of 2021 Potential legislation similar to H.R. 4168/S. 2005, Mandatory Materiality Act Potential legislation similar to H.R. 5488/S. 2805, Protecting Our Courts from Foreign Manipulation Act of 2023 Potential legislation similar to H.R. 6623/S. 2068, Main Street Growth Act Potential legislation similar to H.R. 9924, Litigation Transparency Act of 2024 Potential legislation to repeal the SECs Universal Proxy Rule of 2021 Potential legislation to expand Well Known Seasoned Issuer eligibility Potential legislation to amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to repeal certain rulemaking requirements Nomination of Jonathan Gould to be the Comptroller of the Currency (OCC) Nomination of Michelle Bowman as Vice Chair of Supervision for the Federal Reserve Board of Governors Nomination of Paul Atkins to be Chairman of the Securities and Exchange Commission (SEC) SEC Proposed Rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors (87 Fed. Reg. 21,334-21,473, April 11, 2022) Final Rule, Securities Exchange Commission, on Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure (88 Fed. Reg. 51,896-51,945, September 5, 2023) Proposed Rule, Consumer Financial Protection Bureau; Protecting Americans from Harmful Data Broker Practices (Regulation V) (89 Fed. Reg. 101,402, December 13, 2024) Various issues relating to SEC Best Interest and Enhancing Investment Adviser Regulation relating to broker-dealers, registered investment advisers, conflicts of interest; potential federal preemption of state fiduciary standards; CFTCs de minimis Exception for Swap Dealers; Securities and Exchange Commission amendments to the Commissioners whistleblower rules file no. S7-16-18; proxy process, proxy advisory firms, and other related aspects of corporate governance; corporate common ownership; adoption of the current expected credit loss (CECL) accounting standard; role of credit reporting agencies (CRAs) in the U.S. economy; debt collection practices (regulation F) under the Fair Debt Collection Practices Act (P.L. 95-109); qualified mortgage definition under the Truth in Lending Act (P.L. 90-321) (Regulation Z); Financial Stability Oversight Council activities, including the approach to and designation of systemic importance and risk of nonbank financial companies and firms; Federal Reserve Systems Large Institution Supervision Coordinating Committee; potential housing finance reform legislation; enforcement of Securities and Exchange Commission penalties; federal interest rate authority; Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) reform; electronic consent-based SSN Verification Service (eCBSV); environmental, social, and governance (ESG) enforcement; information collection under the Community Reinvestment Act (CRA) (P.L. 95-128); potential Financial Transaction Tax (FTT); potential Treasury Department proposal relating to tax reporting by banks; investment company cross trading; potential money market fund reform measures; transition to the secured overnight financing rate; implementation of SEC Rule 15c2-11; Department of Labor fiduciary advice exemption: PTE 2020-02; benefits of risk-based pricing; mobile disclosures; modernization of the Credit Repair Organizations Act (enacted as Title IV of the Consumer Credit Protection Act, P.L. 90-321); Internal Revenue Service Priority Guidance Plan; Financial Accounting Standards Board improvements to income tax disclosures; Climate-Related Financial Risk Management for Large Banks; Consumer Financial Protection Bureau (CFPB) regulatory sandbox for disclosures; CFPB Policy Fellowship program; CFPB amendment of its Supervision and Examination Manual; CFPB conflation of Distinct Statutory Concepts of Unfairness and Discrimination; CFPB Small Business Advisory Review Panels Rulemaking on Personal Financial Data Rights; CFPB implementation of the Small Business Lending Data Collection Rule (the 1071 Rule); SEC Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting (File Number S7-26-22); Federal Deposit Insurance Corporation Proposal on Corporate Governance and Risk Management; Basel III Endgame Rule; FDIC Monitoring of Investment Funds Passivity Agreements; issues related to the Export-Import Bank of the United States; European Unions (EU) Corporate Sustainability Due Diligence Directive (CSDDD); Consumer Financial Protection Circular 2024-05, Improper Overdraft Opt-In Practices; Executive Order 14036, Promoting Competition in the American Economy; recommendations for Securities and Exchange Commission regulatory agenda; EU sustainable finance action plan and incorporating ESG factors into financial services; reporting metrics of American companies under the EUs Corporate Sustainability Reporting Directive and Corporate Sustainability Due Diligence Directive; reform to the function of the Public Company Accounting Oversight Board; rulemaking regarding corporate exemptions for shareholder proposals under SEC Rule 14a-8; index fund passivity; rulemaking regarding reform to the proxy voting advice industry at the SEC; request for comment from SEC on potential revisions to executive compensation disclosure; request for comment from SEC on potential revisions to definition of Foreign Private Issuer; SEC Compliance and Disclosure Interpretations: Regulation 13D-G (February 11, 2025); potential policy affirming materiality as the standard for corporate disclosure at the SEC; draft report language proposed for Appropriations FSGG to direct the SEC to update regulations to promote e-delivery of information to investors; draft report language proposed for Appropriations FSGG to restore the 2019 Guidance regarding the designation of nonbank financial firms as systemically important institutions; oversight issues and potential legislation on third party litigation funding, including its national security implications

Client expense: $19,340,000 · Firm income: Not reported

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

H.R. 654, TABS Act of 2025 H.R. 940, Fair Audits and Inspections for Regulators (FAIR) Exams Act H.R. 1602, Financial Privacy Act of 2025 H.R. 1900, Bank Failure Prevention Act of 2025 H.R. 2702/S. 875, Financial Integrity and Regulation Management (FIRM) Act H.R. 3230, Financial Institution Regulatory Tailoring Enhancement Act H.R. 3379, Halting Uncertain Methods and Practices in Supervision Act of 2025 H.R. 3380, Taking Account of Institutions with Low Operation Risk (TAILOR) Act of 2025 H.J. Res. 59/S.J. Res. 18, Disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Overdraft Lending: Very Large Financial Institutions" H.J. Res. 64/S.J. Res. 28, Disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications" H.J. Res. 74/S.J. Res. 36, Disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information (Regulation V)" Draft legislation titled To amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to repeal certain rulemaking requirements Potential legislation regarding the funding of the Consumer Financial Protection Bureau Proposed Rule, Consumer Financial Protection Bureau; Overdraft Lending: Very Large Financial Institutions (89 Fed. Reg. 13,852-13,908, February 23, 2024) Proposed Rule, Federal Deposit Insurance Corporation, Statement of Policy on Bank Merger Transactions (89 Fed. Reg. 29,222-29,244, June 18, 2024) Proposed Rule, Consumer Financial Protection Bureau: Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information (Regulation V) (89 Fed. Reg. 51,682-51,736, June 18, 2024) Proposed Rule, Federal Deposit Insurance Corporation; Regulations Implementing the Change in Bank Control Act (89 Fed. Reg. 67,002-67,009, August 19, 2024) Proposed Rule, Federal Deposit Insurance Corporation: Unsafe and Unsound Banking Practices: Brokered Deposits Restrictions (89 Fed. Reg. 68,244-68,272, August 23, 2024) Proposed Rule, Consumer Financial Protection Bureau; Protecting Americans from Harmful Data Broker Practices (Regulation V) (88 Fed. Reg. 101,402-101,462, December 13, 2024) Advance Notice of Proposed Rulemaking, Consumer Financial Protection Bureau; Fair Credit Reporting Act (Regulation V); Identity Theft and Coerced Debt (89 Fed. Reg. 100,922-100,923, December 13, 2024) Proposed Rule, Consumer Financial Protection Bureau; Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications (88 Fed. Reg. 80,197-80,216, November 17, 2023) Final Rule, Consumer Financial Protection Bureau; Credit Card Penalty Fees (Regulation Z) (89 Fed. Reg. 19,128-19,223, March 15, 2024) Proposed Rule, Federal Reserve Board: Modifications to the Capital Plan Rule and Stress Capital Buffer Requirement (90 Fed. Reg. 16,843-16,860, April 22, 2025) Various issues relating to Regulatory Capital Rules: Regulatory Capital, Implementation of Basel III, Capital Adequacy, Transition Provisions, Prompt Corrective Action, Standardized Approach for Risk-weighted Assets, Market Discipline and Disclosure Requirements, Advanced Approaches Risk-Based Capital Rule, and Market Risk Capital Rule; potential rulemaking regarding Section 956 of the Dodd-Frank Act (P.L. 111-203); independent monetary policy by the Federal Reserve System

Client expense: $19,340,000 · Firm income: Not reported

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

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;

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

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

S. 875, S.401, H.R. 2702- Discussed bank regulatory policy. Discussed home mortgage loan originations, servicing and refinancing, and related issues.

Client expense: $1,180,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), SENATE

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

Client expense: $1,960,000 · Firm income: Not reported

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

Low Income Housing Tax Credit issues, including HR 2725/S. 1515, Affordable Housing Credit Improvement Act; H.R. 1900, Bank Failure Prevention Act of 2025 (issues related to bank merger process); H.R. 2702/S. 875, Financial Integrity and Regulation Management (FIRM) Act; issues related to tailoring prudential regulations for regional banks; issues related to deposit insurance reform; cannabis banking legislation; legislative framework for digital assets regulation, including S.394, GENIUS Act and H.R.2392, STABLE Act; H.R. 1, One Big Beautiful Bill Act (issues related to tax)

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

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

Met with the House and Senate on preemption issues Met with the House and Senate on issues impacting large global banks Met with the House and Senate on digital assets Met with the House and Senate on sanctions legislation Met with the House and Senate on market regulations Met with the House and Senate on bank capital regulations Met with the House and Senate on credit card pricing Met with the House and Senate on AML regulations Met with the House and Senate on geopolitical issues impacting the global economy, including China Met with the House and Senate on proposals related to outbound investment Met with the House and Senate on artificial intelligence Met with the House and Senate on fair access to banking issues and legislative proposals Met with the House and Senate on cybersecurity issues Met with the House and Senate on interchange issues/previously introduced Credit Card Competition Act Met with the House and Senate on bank supervision issues Met with House and Senate on provisions in the One Big Beautiful Bill Act related to the Office of Financial Research and the Secured Overnight Financing Rate Draft legislation - Banking Regulator Accountability Act - all provisions H.R.2392, Stablecoin Transparency and Accountability for a Better Ledger Economy Act of 2025 - all provisions H.R.2548/S.1241, Sanctions Russia Act of 2025 - all provisions H.R.3655, Digital Market Clarity Act of 2025 - all provisions S.401/H.R.987, Fair Access to Banking Act - all provisions S.875/H.R.2702, Financial Integrity and Regulation Management (FIRM) Act - all provisions S.919/S.1582, Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act - all provisions S.1053/H.R.2246, Foreign Investment Guardrails to Help Thwart (FIGHT) China Act of 2025 - all provisions S.1582, GENIUS Act - all provisions S.2381/H.R.1944, the 10 Percent Credit Card Interest Rate Cap Act - all provisions

Client expense: $1,250,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

All legislation related to consumer lending regulation and consumer lending policy. Issues related to APR caps and de-risking. S. 875, The Financial Integrity and Regulation Management Act. H.R. 2702, The Financial Integrity and Regulation Management Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

A bill to require the Director of the United States Fish and Wildlife Service to reissue a final rule removing the gray wolf... (S.1306); America the Beautiful Act (S.1547); Combating Organized Retail Crime Act (S.1404); ESA Amendments Act (H.R.1897); Expanding Public Lands Outdoor Recreation Experiences (EXPLORE) Act (H.R.6492 in 118th); Fair Access to Banking Act (S.401 / H.R.987); FFL Protection Act (H.R.1773); Fighting Irrational Regulatory Enforcement to Avert Retailers' Misfortune (FIREARM) Act (S.1922 / H.R.3770); Financial Integrity and Regulation Management (FIRM) Act (S.875 / H.R. 2702); Firearm Industry Nondiscrimination (FIND) Act (H.R.45 / S.137); Freedom from Unfair Gun Taxes Act of 2025 (S.1169 / H.R.2442); FY26 Appropriations- Agriculture, Rural Development, Food and Drug Administration; FY26 Appropriations-Commerce, Justice, Science and Related Agencies; FY26 Appropriations-Defense; FY26 Appropriations-Financial Services & General Government; FY26 Appropriations-Interior, Environment, and Related Agencies; FY26 Appropriations-Military Construction, Veterans Affairs, and Related Agencies; Hearing Protection Act (H.R.404 / S.364); Law Enforcement Protection and Privacy Act (H.R.1698); National Defense Authorization Act / Ammunition Supply Chain; No Frivolous Applications for Short-Barreled Shotguns Act (H.R.3034); One Big Beautiful Bill Act (H.R.1); Pet and Livestock Protection Act of 2025 (H.R.845); Presidential Nominations of Various Federal Departments and Agencies; PROTECT the Second Amendment Act (H.R.2930); Protecting Americans Right to Silence (PARTS) Act (H.R.631 / S.1039); Protecting Access for Hunters and Anglers Act (H.R.556 / S.537); Protecting Communities and Preserving the Second Amendment Act (S.1652); Protecting Privacy in Purchases Act (H.R.1181); Protecting the Right to Keep and Bear Arms Act (H.R.2039); Reining in Federal Licensing Enforcement (RIFLE) Act (H.R.624); Repealing Illegal Freedom and Liberty Excises (RIFLE) Act (H.R.2552 / S.1224); Saving Our Veterans Lives Act (H.R.1987 / S.926); SHORT Act (H.R.2395 / S.1162); Supporting the Second Amendment's guaranteeand eliminating any of the Biden administration's infringements on American's constitutional freedoms (H.Res.339); The Protecting the Mailing of Firearms Act (H.R.3033); Travelers Gun Rights Act (S.966 / H.R.2060); USFWS Proposed Rule 2025-2026 Station-Specific Hunting and Sport Fishing Regulations; and Veterans 2nd Amendment Protection Act (S.478 / H.R.1041).

Client expense: $1,780,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Protect the credit union tax exemption Support legislation and regulation that advance credit unions and their over 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)

Client expense: $1,170,000 · Firm income: Not reported

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

Met with the House and Senate on preemption issues Met with the House and Senate on issues impacting large global banks Met with the House and Senate on digital assets Met with the House and Senate on sanctions legislation Met with the House and Senate on market regulations Met with the House and Senate on bank capital regulations Met with the House and Senate on credit card pricing Met with the House and Senate on AML regulations Met with the House and Senate on geopolitical issues impacting the global economy, including China Met with the House and Senate on proposals related to outbound investment Met with the House and Senate on artificial intelligence Met with the House and Senate on fair access to banking issues and legislative proposals Met with the House and Senate on cybersecurity issues Met with the House and Senate on interchange issues/previously introduced Credit Card Competition Act Met with the House and Senate on bank supervision issues H.R.2392, the Stablecoin Transparency and Accountability for a Better Ledger Economy Act of 2025 - all provisions S.401/H.R.987, Fair Access to Banking Act - all provisions S.875/H.R.2702, Financial Integrity and Regulation Management (FIRM) Act - all provisions S.919, Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act - all provisions S.1053/H.R.2246, Foreign Investment Guardrails to Help Thwart (FIGHT) China Act of 2025 - all provisions S.2381/H.R.1944, the 10 Percent Credit Card Interest Rate Cap Act - all provisions

Client expense: $1,420,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 478/S. 113, Promoting New Bank Formation Act S. 875/H.R. 2702, Financial Integrity and Regulation Management (FIRM) Act 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 STABLE Act of 2025 S. 394, the GENIUS Act of 2025 S. 919, the GENIUS Act of 2025 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. 2702/S. 875, the Financial Integrity and Regulation Management (FIRM) Act Consumer Financial Protection Commission Act H.R. 1653, the CID Reform Act Business of Insurance Regulatory Reform Act CFPB-IG Reform Act CFPB Dual Mandate and Economic Analysis Act 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 Homebuyers Privacy Protection Act

Client expense: $1,730,000 · Firm income: Not reported

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