Business of Insurance Regulatory Reform Act of 2025

Protect the credit union tax exemption Support legislation and regulation that advance credit unions and their over 146 million members Support regulatory relief for credit unions Support holistic evaluation of regulatory burden on credit unions Support modification of credit union loan maturity limits Support credit union field of membership expansion and modernization Support regulator- and bank-approved credit union-bank mergers Support financial inclusion and increased access to financial services Support modifying the credit union member business lending cap Support NCUAs existence as an independent regulator and insurer of credit unions Support assistance for minority depository institution credit unions Support regulatory relief for de novo credit unions Support harmonization of federal cyber incident notification standards Oppose Community Reinvestment Act requirements for credit unions Oppose legislative action to restrict credit union overdraft and courtesy pay programs Support regulatory framework for artificial intelligence that allows responsible innovation and recognizes credit unions compliance with existing regulations Support allowing use of artificial intelligence for regulatory reporting purposes Support mandatory arbitration agreements Oppose national interest rate cap Oppose national credit card interest rate cap Support expanded natural person and corporate credit union investment authority Support expanded credit union examination cycle Support increased examination transparency Support regulatory policies to promote innovation and access to credit Support Central Liquidity Facility and Community Development Revolving Loan Fund enhancements Oppose NCUA examination of credit union vendors Oppose National Credit Union Share Insurance Fund structural changes or premium assessment Support parity in deposit insurance coverage levels between credit unions and banks Oppose additional Call Report fields on loans to credit union officials and senior executive staff Oppose additional Call Report fields on maturity distribution of uninsured shares Oppose NCUA Call Report collection of overdraft and NSF fee revenue data Support modernization and simplification of Call Report form and instructions Oppose collection of vendor information in NCUA Credit Union Profile Oppose changes to NCUA collection forms outside rulemaking process Support NCUA review of normal operating level and methodology Oppose NCUA rule on succession planning Oppose excessive NCUA requirements for supervisory committee audits Support NCUA action to reduce scope of supervisory committee examination Support NCUA recognition of digital banking in service facility definition Support clarification of NCUA member expulsion regulations Support NCUA proposed rule on increasing overdraft flexibility Support NCUA recognition of government sponsored enterprises as government agencies for loan maturity limit purposes Support NCUA adoption of floating interest rate cap Support modification of NCUA commercial loan definition Support increased flexibility in NCUA occupancy requirements Support NCUA action to clarify loan participation limits Support NCUA modification of low-income designation process Support expanding NCUA qualified charity definition Support allowing greater weighted average life for corporate credit unions financial assets Support extension of maturity limit for corporate credit union borrowing Support increased flexibility for advertising and notice of insured status Support increased compliance timeline for NCUA simplification of share insurance rule Support balanced implementation of debanking executive order Support increased NCUA efforts to promote credit union industry Support modernization and streamlining of NCUA operations Support NCUA supervisory flexibility for credit union shutdown assistance efforts Support NCUA and FFIEC action to modernize CAMELS rating system Support modernization of NCUA fidelity bond review requirements Support increased threshold for Depository Institution Management Interlocks Act major assets prohibition Support clarification of Federal Credit Union Act preemption of state interchange laws Support making CFPB subject to regular appropriations process Support increased CFPB budget transparency Support restructuring CFPB leadership to a bipartisan commission Support creation of a CFPB Inspector General Support reforms to CFPB Civil Investigative Demand process Support increasing and indexing asset thresholds for CFPB supervision of credit unions Support clarification of CFPB unfair, deceptive, or abusive acts and practices authority Support CFPB use of Section 1022 authority to exempt credit unions from certain regulations Support CFPB oversight and monitoring of nonbank entities Oppose CFPB efforts to avoid requirements of the rulemaking process Support CFPB use and disclosure of relevant data in rulemakings Support CFPB use of cost-benefit analysis in rulemaking process Support CFPB coordination with NCUA on policy matters and examination scheduling Oppose mislabeling financial services fees as junk fees Oppose arbitrary limits on credit union fee income Oppose CFPB efforts to restrict information in credit reports Support CFPB engaging in ongoing retrospective review of past regulations Support CFPB consumer complaint database reforms Support CFPB no-action letter program with extended timeline and increased protection of sensitive strategic information Oppose expansion of consumer report and consumer reporting agency definitions under the Fair Credit Reporting Act/Regulation V Support consumer protection regulations for buy-now-pay-later loan providers Support inclusion of buy-now-pay-later loans in FHA underwriting Support CFPB use of Civil Penalty Fund for consumer financial education Support increase of Home Mortgage Disclosure Act reporting thresholds Support reforms to increase flexibility for TILA-RESPA Integrated Disclosure requirements Support inclusion of eligibility language for VA loans in FHA Informed Consumer Choice Disclosure Notice Support credit union access to universal service fund letters of credit program Support federal data privacy and security standard that exempts Gramm-Leach-Bliley Act covered institutions, preempts state laws, operates on an opt-out basis, recognizes the complexity of data deletion, and does not authorize private right of action Support increased transparency for fintech bank charter applications Support Treasury development of model forms and qualified vehicle list for auto loan interest deduction Support safe harbor for credit unions related to the auto loan interest deduction Support clarification of remittance transfer tax exemptions Support inclusion of credit unions in Trump Accounts program Oppose development of a central bank digital currency Support credit union access to Federal Reserve liquidity options Support gradual expansion of Fedwire and National Settlement Service operating hours with optional participation Oppose addition of fourth same-day ACH window Support expanded flexibility for accessing the Fed discount window and intraday credit Oppose expanded eligibility for Federal Reserve master account access Oppose Regulation II debit interchange fee cap Oppose Federal Reserve proposed rule on modifying Regulation II debit interchange cap Support improvements to the Federal Reserves Debit Card Issuer Survey Oppose legislative action to impose caps or restrictions on debit or credit interchange fees Oppose legislative action to prohibit the Federal Reserve from paying interest on reserves Support Federal Reserve action to coordinate regulatory guidance on penny circulation issues and management of penny supply Support continued offering of Federal Reserve check services Oppose expansion of Electronic Fund Transfer Act/Regulation E financial institution liability Support fair distribution of Electronic Fund Transfer Act/Regulation E error resolution responsibilities Support clarification of funds definition under Electronic Fund Transfer Act/Regulation E Support clarification of Electronic Fund Transfer Act/Regulation E treatment of digital assets Support increased flexibility for check holds and funds availability requirements Support transition to electronic payments for government payments Support clarification of Section 314(b) information sharing safe harbor for identifying and preventing payments fraud and additional flexibility for annual renewal requirement Support greater flexibility for credit unions to decline services with clear indicia of fraud or elder abuse Support parity for credit union provision of digital asset services and related regulations Prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products Support Treasury and NCUA action to implement regulatory framework for stablecoin issuance Support NCUAs role as primary regulator of credit unions stablecoin activities Oppose treating stablecoins or digital assets as federally insured Oppose payment of interest, yield, or rewards on stablecoin holdings Support digital assets guardrails to prevent deposit outflows Support clarifying credit unions authority to provide custodial services for their members Support safeguards for rehypothecation of digital assets Support reduced government-sponsored enterprises costs for credit union mortgages Support secondary mortgage market access for credit unions Support continued role for FHFA as an independent regulator Support credit union access to Federal Home Loan Bank system Support expansion of Federal Home Loan Bank Act community financial institution definition Support Federal Home Loan Bank engagement with credit unions Oppose adoption of volume-based incentives for Federal Home Loan Banks Support Federal Home Loan Bank allocations to the Affordable Housing Program Support FinCEN implementation of the Corporate Transparency Act Support risk-based approach to anti-money laundering/countering financing of terrorism program requirements Support increasing Currency Transaction Report and Suspicious Activity Report filing thresholds Support streamlining Currency Transaction Report and Suspicious Activity Report forms Support increased inclusion of identifiable information in Section 314(a) information requests Support consistency between NCUA and FinCEN requirements on Bank Secrecy Act compliance Support FinCEN survey to accurately measure Bank Secrecy Act compliance costs Support DOD clarification of Military Lending Act and Servicemembers Civil Relief Act requirements Support standardized disclosures and financial literacy briefings for servicemembers Support credit union access to nominal leases on military installations Oppose nominal leases for banks on military installations Oppose legislative action on the Overseas Military Banking Program Oppose inclusion of interchange, interest rate cap, or fraud liability amendments in the National Defense Authorization Act Support inclusion of currency transaction report/suspicious activity report thresholds and veterans member business lending amendments in the National Defense Authorization Act Support federal share insurance for all credit unions acting as fiscal agents of the U.S. government Support role of Community Development Financial Institutions Fund in promoting economic growth and access to capital in underserved communities Support access to Community Development Financial Institutions Fund awards and technical assistance for credit unions Support Community Development Financial Institutions Fund bond guarantee program Support Community Development Financial Institutions Fund liquidity enhancement pilot program Support disbursement of all Community Development Financial Institution Fund appropriated award funding without additional barriers Support timely completion of Emergency Capital Investment Program disposition agreements Oppose reclassification of credit header information as a consumer report Oppose reliance on single source of documentation to determine instances of identity theft or coerced debt Oppose use of interim final rule to modify personal financial data rights requirements Support modification of Section 1033 rule to allow data providers to charge fees, remove prescriptive technology standards, and establish data privacy standards and allocation of liability Support modernization of e-signature requirements Support allowing electronic or documented oral credit card applications Support increased flexibility for disclosures Support rescission of CFPB payday lending rule payment provisions Support modification of FCC revocation of consent rule Support greater flexibility for FCC fraud alert exemption Support FCC efforts to combat illegal robocalls and robotexts Support uniform federal standards and increased federal preemption of state laws on interchange, data privacy, artificial intelligence, and elder financial abuse reporting Support federal safe harbor for provision of financial services to marijuana-related businesses that comply with state laws Issues related to housing finance reform Issues related to flood insurance Issues related to privately insured credit unions Issues related to credit union capital requirements Issues related to credit union conversions Issues related to credit unions as employers Issues related to the Foreign Account Tax Compliance Act Issues related to fair lending Issues related to the Telephone Consumer Protection Act Support nomination of John Crews as a member of the NCUA Board Support Credit Union Board Modernization Act (H.R. 975; S. 522) Support 1071 Repeal to Protect Small Business Lending Act (H.R. 976; S. 557) Support Making the CFPB Accountable to Small Businesses Act (H.R. 1606) Support Financial Integrity and Regulation Management Act (S. 875; H.R. 2702; Senate Amendment 3104) Support Fair Audits and Inspections for Regulators Exams Act (H.R. 940; S. 5335) Support Small LENDER Act (H.R. 941) Support Anti-CBDC Surveillance State Act (H.R. 1919; S. 1124) Support Veterans Member Business Loan Act (H.R. 507; S. 110; Senate Amendment 3776) Support Taking Account of Bureaucrats Spending Act (H.R. 654) Support Rectifying UDAAP Act (H.R. 1652) Support Civil Investigative Demand Reform Act (H.R. 1653) Support SECURE Notarization Act (H.R. 1777; S. 1561) Support Increasing Credit Union Lending for Business Growth Act (H.R. 1791) Support Financial Reporting Threshold Modernization Act (H.R. 1799; Amendment 715 to H.R. 3838) Support Home of Your Own Act (H.R. 2064) Support Homes for Every Local Protector, Educator, and Responder Act (H.R. 2094; S. 978) Support CFPB Dual Mandate and Economic Analysis Act (H.R. 2183) Support Transparency in CFPB Cost-Benefit Analysis Act (H.R. 2331) Support CFPB-IG Reform Act (H.R. 2513) Support Financial Institution Regulatory Tailoring Enhancement Act (H.R. 3230) Support Halting Uncertain Methods and Practices in Supervision Act (H.R. 3379) Support Taking Account of Institutions with Low Operation Risk Act (H.R. 3380) Support Bureau of Consumer Financial Protection Commission Act (H.R. 3445) Support Advancing the Mentor-Protege Program for Small Financial Institutions Act (H.R. 3709) Support Expanding Access to Lending Options Act (H.R. 4167; S. 3616) Support CDFI Bond Guarantee Program Improvement Act (S. 1880) Support Taskforce for Recognizing and Averting Payment Scams Act (H.R. 4936; S. 2019; Senate Amendment 3257) Support Capping Excessive Awarding of SBLC Entrants Act (H.R. 2987) Support Supervisory Modifications for Appropriate Risk-Based Testing Act (H.R. 4437) Support Stop Agency Fiat Enforcement Act (H.R. 4460) Support American Access to Banking Act (H.R. 4544) Support Protecting Access to Credit for Small Businesses Act (S. 2486) Support Business of Insurance Regulatory Reform Act (H.R. 4735; S. 2419) Support NCUA Central Liquidity Facility Enhancement Act (S. 2545, S. 3575; Senate Amendments 3722, 3834, 4384, 5882, 6180) Support CDFI Fund Transparency Act (S. 2704; Senate Amendments 3640, 3732; H.R. 7775) Support Supporting Upgraded Property Projects and Lending for Yards Act (H.R. 4568) Support Unleashing AI Innovation in Financial Services Act (H.R. 4801) Support AI Practices, Logistics, Actions, and Necessities Act (H.R. 2152) Support Streamlining Transaction Reporting and Ensuring Anti-Money Laundering Improvements for a New Era Act (S. 3017; Senate Amendment 6241) Support NFIP Continuation Act (H.R. 5577) Support 21st Century ROAD to Housing Act (H.R. 6644) Support Regulatory Efficiency, Verification, Itemization, and Enhanced Workflow Act (H.R. 6544) Support Community Bank Regulatory Tailoring Act (H.R. 7056) Support Close the Shadow Banking Loophole Act (S. 3734) Support American Lending Fairness Act (S. 3889; H.R. 7866) Support Community Bank Relief Act (S. 3849; H.R. 7484) Support Access to Fair Financing for Opportunity and Resilient Development Act (Senate Amendments 4354, 4394, 6101; S. 3940) Support Main Street Depositor Protection Act (S. 4198; Senate Amendment 6396) Support Growing Deposit Insurance for the Future Act (H.R. 8088) Support ESCRA Act (H.R. 306) Support Credit Access and Inclusion Act (H.R. 5402; S. 1465) Support FCRA Liability Harmonization Act (H.R. 5775) Support Guarding Unprotected Aging Retirees from Deception Act (H.R. 2978; S. 2544; Senate Amendment 6471) Support MORE Opportunities for Homeownership Act (H.R. 7647) Support Eliminating Fraud in the CFPBs Complaint Database Act (H.R. 7588) Support Fair Credit Reporting Reseller Accuracy Act (H.R. 8141) Support Bank Fraud Technology Advancement Act (H.R. 8671) Support STOP Payments Fraud Act (H.R. 9331) Support emergency transaction account guarantee legislation (H.R. 8075) Support Credit Union Investment Authority Act (H.R. 10082) Support CFPB Reform Act (H.R. 10184) Support inclusion of guidance on penny circulation and rounding in Common Cents Act (H.R. 3074, H.R. 10167; S. 1525) Support parity for credit unions and prohibition on stablecoin yield in Digital Asset Market Clarity Act (H.R. 3633) Support inclusion of additional credit union provisions in Main Street Capital Access Act (H.R. 6955) Oppose Repealing Big Brother Overreach Act (H.R. 425; S. 100) Oppose 10 Percent Credit Card Interest Rate Cap Act (H.R. 1944; S. 381; Senate Amendment 2239) Oppose Credit Card Competition Act (Senate Amendments 2229, 2230, 2345, 4305; S. 3623; H.R. 7035) Oppose commissary interchange fee study (Senate Amendment 3216) Oppose commissary coupon pilot program (Senate Amendments 5942, 6034) Oppose End the Feds Big Bank Bailout Act (S. 2113; Senate Amendment 3761) Oppose Credit Card Fairness Act (S. 3660) Oppose Strengthening Oversight for the Financial Sector Act (H.R. 10230) Oppose S.J.Res. 130, on CFPB overdraft circular Oppose S.J.Res. 132, on CFPB examinations for risks to servicemembers Oppose S.J.Res. 141, on deceptive collection of medical debt

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

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

Support HR 4735/S 2419 Business of Insurance Regulatory Reform Act - keeps insurance regulated by the states and not by the Consumer Financial Protection Bureau or set by international bodies. This bill has been folded into H.R. 10184, the Consumer Financial Protection Accountability and Reform Act of 2026. Oppose H.R. 10439 Veterans and Consumers Fair Credit - would apply all in APR to state credit unions that offer voluntary insurance protection produces. Advocate to preserve consumer access to voluntary insurance protection products in legislative proposals redefining APR calculations. Advocate for federal preemption of privacy measures in line with GLBA and HIPAA as applied to financial services. o H.R. 8413, SECURE Data Act, a comprehensive federal privacy framework and H.R. 8398, GUARD Financial Data Act. Support HR 7128/S 4395, the TRIA Program Reauthorization Act of 2026, which would provide for a reauthorization of the Department of the Treasurys Terrorism Risk Insurance Program through 2034.

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

Support HR 4735/S 2419 Business of Insurance Regulatory Reform Act - keeps insurance regulated by the states and not by the Consumer Financial Protection Bureau or set by international bodies. This bill has been folded into H.R. 10184, the Consumer Financial Protection Accountability and Reform Act of 2026. Oppose H.R. 10439 Veterans and Consumers Fair Credit - would apply all in APR to state credit unions that offer voluntary insurance protection produces. Advocate to preserve consumer access to voluntary insurance protection products in legislative proposals redefining APR calculations Advocate for federal preemption of privacy measures in line with GLBA and HIPAA as applied to financial services. o H.R. 8413, SECURE Data Act, a comprehensive federal privacy framework and H.R. 8398, GUARD Financial Data Act. Support HR 2441/S 1877 Improving Disclosure for Investors Act - to provide electronic delivery of SEC regulatory documents. Provision included in H.R. 3383, the INVEST Act. Support HR 1777/S 1561 SECURE Notarization Act - authorizes notaries to perform, and to establish minimum standards for electronic notarizations and remote notarizations. Support increased CDFI and MDI funding in FY 2026 & 2027 Appropriations. Support preservation of the CDFI Fund. Oppose S. 3623/H.R. 7035, the Credit Card Competition Act, a bill that would reduce interchange fees on credit cards. Support the Retirement Fairness for Charities and Educational Institutions Act (HR 1013/S 424). Allows 403(b) retirement plans to invest in unregistered insurance contracts and CITs. Provision included in H.R. 3383, the INVEST Act. Support the TRAPs Act (Task Force for Recognizing and Averting Payment Scams) (HR 4936/S 2019) and other legislation that protects consumers from payment scams and fraud. Support H.R. 9331, Strengthening Transaction Oversight and Preventing (STOP) Payments Fraud Act, to address check fraud. Support S. 3940, the Access to Fair Financing for Opportunity and Resilient Development (AFFORD) Act, which brings together four CDFI bills that would support CDFI secondary markets and access to capital through the Bond Guarantee Program, among other improvements. Monitor how federal AI legislation impacts insurers ability to conduct business. Monitor H.R. 3633, the Digital Asset Market Clarity (CLARITY) Act and how federal digital asset market structure legislation impacts insurers ability to offer a stablecoin.

H.R. 4735/S. 2419 - Business of Insurance Regulatory Reform Act (To amend the Consumer Financial Protection Act of 2010 to clarify the authority of the Bureau of Consumer Financial Protection with respect to persons regulated by a State insurance regulator. Issue: Business of Insurance.) H.R. 643 FIO Elimination Act (This bill eliminates the Federal Insurance Office (FIO) within the Department of the Treasury. The bill also removes the FIO director as a nonvoting member of the Financial Stability Oversight Council.) S. 1544/H.R. 3437 - Insurance Data Protection Act. To prohibit the Federal Insurance Office of the Department of the Treasury and other financial regulators from collecting data directly from an insurance company. Issue: FIO Reform H.R. 4583 and H.R. 4582/S.1552 - Living Donor Protection Act. The bill would promote and protect from discrimination living organ donors. Issue: underwriting. H.R. 3383 - Incentivizing New Ventures and Economic Strength Through Capital Formation (INVEST) Act of 2025. This bill allows a closed-end fund-a portfolio of pooled assets with a limited number of shares traded on an exchange-to increase its investment in private investment funds. Specifically, the Securities and Exchange Commission is prohibited from limiting the sale or listing of securities of a closed-end fund that invests in private investment funds. This bill also apples to a closed-end company treated as a business development company. Issue: Capital formation H.R. 7130 - McCarran-Ferguson Restoration Act. The bill would eliminate the Federal Insurance Office of the Department of the Treasury and establish a United States Insurance Representative within the Department of the Treasury. Issue: FIO Reform.

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

H.R.292 - To amend the Federal Crop Insurance Act to require the Federal Crop Insurance Corporation to carry out research and development regarding a policy to insure table, wine, and juice grapes against losses due to a freeze event, and for other purposes. H.R.550 - To require the Government Accountability Office to conduct a study regarding insurance coverage for damages from wildfires, and for other purposes. H.R.643 - To eliminate the Federal Insurance Office of the Department of the Treasury, and for other purposes. H.R.827 - To ensure the availability and affordability of homeowners' insurance coverage for catastrophic events. H.R.1481 - To amend the Internal Revenue Code of 1986 to establish a system for the taxation of catastrophic risk transfer companies to ensure sufficient capital to cover catastrophic insurance losses, and for other purposes. H.R.2123 - To amend the National Flood Insurance Act of 1968 to reauthorize the National Flood Insurance Program. S.586 - A bill to amend the Internal Revenue Code of 1986 to provide an advance refundable credit to offset certain flood insurance premiums, and for other purposes. S.824 - A bill to reauthorize the National Flood Insurance Program. H.R.2547 - To amend the Internal Revenue Code of 1986 to exclude debt held by certain insurance companies from capital assets and to extend capital loss carryovers for such companies from 5 years to 10 years. H.R.2567 - To amend the Internal Revenue Code of 1986 to provide special rules for purposes of determining if financial guaranty insurance companies are qualifying insurance corporations under the passive foreign investment company rules. H.R.2822 - To extend the National Flood Insurance Program through December 31, 2026. H.R.3437 - To prohibit the Federal Insurance Office of the Department of the Treasury and other financial regulators from collecting data directly from an insurance company. H.R.3664 - To prohibit private passenger automobile insurers from using certain income proxies to determine insurance rates and eligibility. H.R.3800 - To amend the National Flood Insurance Act of 1968 to prohibit the deferral of the issuance of letters of map revision based on the placement of fill or conditional letters of map revision based on the placement of fill, and for other purposes. H.R.2774 - To amend section 5 of the Flood Control Act of 1941 to impose a deadline for initiating the repair or restoration of project under such section, and for other purposes. H.R.3300 - To amend the Federal Water Pollution Control Act to clarify that a permit is not required under the National Pollutant Discharge Elimination System for a discharge resulting from the aerial application of certain products used for fire control and suppression, and for other purposes. S.1271 - A bill to amend the Federal Agriculture Improvement and Reform Act of 1996 with respect to transitioning producers from the noninsured crop assistance program to the whole farm revenue insurance plan. S.2053 - A bill to ensure that Write Your Own companies can sell private flood insurance products that compete with National Flood Insurance Program products. S.2054 - A bill to allow National Flood Insurance Program policyholders who leave the program to purchase a private insurance flood policy to return to the National Flood Insurance Program without penalty, and for other purposes. S.1437 - A bill to require the Administrator of the National Aeronautics and Space Administration to establish a program to identify, evaluate, acquire, and disseminate commercial Earth remote sensing data and imagery in order to satisfy the scientific, operational, and educational requirements of the Administration, and for other purposes. H.R.5574 - To extend the National Flood Insurance Program through November 21, 2025. H.R.5577 - NFIP Extension Act of 2026 H.R.5607 - Flood Insurance Transparency Act of 2025 H.R.5608 - To ensure that Write Your Own companies can sell private flood insurance products that compete with National Flood Insurance Program products. H.R.5500 - To make administrative reforms to the National Flood Insurance Program to increase fairness and accuracy and protect the taxpayer from program fraud and abuse, and for other purposes. H.R.5503 - To require the Federal Emergency Management Agency to establish a Territorial Disaster Recovery Program to continuously identify, monitor, and address factors and capability gaps that hinder the execution and completion of recovery activities relating to major disasters by eligible entities located in the territories of the United States. H.R.5504 - To amend the Internal Revenue Code of 1986 to allow for a credit against tax for certain flood insurance expenses. H.R.5229 - To provide for improvements to National Flood Insurance Program rate maps, and for other purposes. H.R.4735 - Business of Insurance Regulatory Reform Act of 2025 H.R.4504 - To require the Secretary of the Treasury to establish a catastrophic property loss reinsurance program, and for other purposes. S.2931 - A bill to reauthorize the National Flood Insurance Program. S.2946 - A bill to reauthorize the National Flood Insurance Program. S.2349 - A bill to require the Secretary of the Treasury to establish a catastrophic property loss reinsurance program, and for other purposes. S.2419 - Business of Insurance Regulatory Reform Act of 2025 H.R.5697 - To adjust the effective date of any adjustment based on Consumer Price Index to rail passenger liability cap that occurs during calendar year 2026. H.R.5848 - NFIP Retroactive Renewal and Reauthorization Act H.R.5961 - To increase the availability of flood insurance for agricultural structures, and for other purposes. H.R.5990 - To require the Secretary of Housing and Urban Development to establish a pilot program to provide grants to implementing organizations to administer a whole-home repairs program for eligible homeowners and eligible landlords, and for other purposes. H.R.6086 - To provide for funding from the Aviation Insurance Revolving Fund to continue certain Federal Aviation Administration activities in the event of a Government shutdown, and for other purposes. H.R.6155 - Federal Carjacking Enforcement Act H.R.6256 - To amend the Homeowner Flood Insurance Affordability Act of 2014 to address ecosystem restoration projects, and for other purposes. H.R.6274 - To establish a Natural Disaster Risk Reinsurance Program, and for other purposes. H.R.6560 - To amend the National Flood Insurance Act of 1968 to provide for the automatic contingent extension of the National Flood Insurance Program, and for other purposes. H.R.6620 - To amend the National Flood Insurance Act of 1968 to allow for the consideration of private flood insurance for the purposes of applying continuous coverage requirements, and for other purposes. H.R.7130 - McCarran-Ferguson Restoration Act H.R.7246 - To establish the Climate Financial Risk Committee and Climate Financial Risk Advisory Committee on the Financial Stability Oversight Council. H.R.7355 - To provide for the disclosure and sharing of certain policy and claims information under the National Flood Insurance Program, and for other purposes. H.R.7462 - To amend the Federal Crop Insurance Act to direct the Secretary of Agriculture to use certain data sets when determining eligibility related to indemnity payments under the Hurricane Insurance Protection-Wind Index endorsement, and for other purposes. H.R.7862 - To amend the National Flood Insurance Act of 1968 to limit the application of the Endangered Species Act with respect to certain actions under the national flood insurance program, and for other purposes. S.3711 - A bill to establish the Climate Financial Risk Committee and Climate Financial Risk Advisory Committee on the Financial Stability Oversight Council. S.3843 - A bill to amend the Federal Crop Insurance Act to direct the Federal Crop Insurance Corporation to conduct research and development on frost or cold weather insurance, and for other purposes. S.4088 - A bill to amend the Federal Crop Insurance Act to improve education and risk management assistance, and for other purposes. S.4215 - A bill to amend the Federal Crop Insurance Act to reduce Federal spending on crop insurance, and for other purposes. H.R.8218 - Fair Compensation for Truck Crash Victims Act H.R.8843 - Federal Accountability for Felony Obstruction Act S.4395/H.R 7128 - Terrorism Risk Insurance Program Reauthorization Act of 2026 S.4651 - Increasing Insurance Access for Specialty Crops Act

NFIP Reauthorization (generally); HR.2123/S.824 - NFIP Extension Act of 2025; HR.643 - Federal Insurance Office Elimination Act; FHFA Property Insurance Requirements; S.1545 - Repeatedly Flooded Communities Preparation Act; HR.3437/S.1544 - Insurance Data Protection Act; HR.4494/S.2313 - The Flood Insurance Relief Act; HR.4735/S.2419 - Business of Insurance Regulatory Reform Act; HR.5577 - NFIP Extension Act of 2026; HR.6620 - To amend the National Flood Insurance Act of 1958 with continuous coverage requirements; HR.7130 - The McCarran-Ferguson Restoration Act; HR.7128 - The TRIA Program Reauthorization Act of 2026; S.4395 - Terrorism Risk Insurance Program Reauthorization Act of 2026

Client expense: $280,000 · Firm income: Not reported

Government targets: Federal Housing Finance Agency (FHFA), 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

Support HR 4735/S 2419 Business of Insurance Regulatory Reform Act - keeps insurance regulated by the states and not by the Consumer Financial Protection Bureau or set by international bodies. Advocate to preserve consumer access to voluntary insurance protection products in legislative proposals redefining APR calculations Advocate for privacy measures in line with GLBA and HIPAA as applied to financial services. o H.R. 8413, SECURE Data Act, a comprehensive federal privacy framework and H.R. 8398, GUARD Financial Data Act. Monitor how federal AI legislation impacts insurers ability to conduct business. Monitor how federal stablecoin market structure legislation impacts insurers ability to conduct business Support HR 7128, the TRIA Program Reauthorization Act of 2026, which would provide for a reauthorization of the Department of the Treasurys Terrorism Risk Insurance Program through 2034.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Support HR 4735/S 2419 Business of Insurance Regulatory Reform Act - keeps insurance regulated by the states and not by the Consumer Financial Protection Bureau or set by international bodies. Advocate to preserve consumer access to voluntary insurance protection products in legislative proposals redefining APR calculations Advocate for privacy measures in line with GLBA and HIPAA as applied to financial services. o H.R. 8413, SECURE Data Act, a comprehensive federal privacy framework and H.R. 8398, GUARD Financial Data Act. Support HR 7128, the TRIA Program Reauthorization Act of 2026, which would provide for a reauthorization of the Department of the Treasurys Terrorism Risk Insurance Program through 2034. Support HR 2441/S 1877 Improving Disclosure for Investors Act - to provide electronic delivery of SEC regulatory documents. Included in the INVEST Act. Support HR 1777/S 1561 SECURE Notarization Act - authorizes notaries to perform, and to establish minimum standards for electronic notarizations and remote notarizations. Support increased CDFI and MDI funding in FY 2026 & 2027 Appropriations. Support preservation of the CDFI Fund. Oppose the S. 3623/H.R. 7035, the Credit Card Competition Act, a bill that would reduce interchange fees on credit cards. Support the Retirement Fairness for Charities and Educational Institutions Act (HR 1013/S 424). Allows 403(b) retirement plans to invest in unregistered insurance contracts and CITs. Included in the INVEST Act. Support the TRAPs Act (Task Force for Recognizing and Averting Payment Scams) (HR 4936/S 2019) and other legislation that protects consumers from payment scams and fraud. Support S. 3940, the Access to Fair Financing for Opportunity and Resilient Development (AFFORD) Act, which brings together four CDFI bills that would support CDFI secondary markets and access to capital through the Bond Guarantee Program, among other improvements.

H.R. 4735/S. 2419 - Business of Insurance Regulatory Reform Act (To amend the Consumer Financial Protection Act of 2010 to clarify the authority of the Bureau of Consumer Financial Protection with respect to persons regulated by a State insurance regulator. Issue: Business of Insurance.) H.R. 643 FIO Elimination Act (This bill eliminates the Federal Insurance Office (FIO) within the Department of the Treasury. The bill also removes the FIO director as a nonvoting member of the Financial Stability Oversight Council.) S. 1544/H.R. 3437 - Insurance Data Protection Act. To prohibit the Federal Insurance Office of the Department of the Treasury and other financial regulators from collecting data directly from an insurance company. Issue: FIO Reform H.R. 4583 and H.R. 4582/S.1552 - Living Donor Protection Act. The bill would promote and protect from discrimination living organ donors. Issue: underwriting. H.R. 3383 - Incentivizing New Ventures and Economic Strength Through Capital Formation (INVEST) Act of 2025. This bill allows a closed-end fund-a portfolio of pooled assets with a limited number of shares traded on an exchange-to increase its investment in private investment funds. Specifically, the Securities and Exchange Commission is prohibited from limiting the sale or listing of securities of a closed-end fund that invests in private investment funds. This bill also apples to a closed-end company treated as a business development company. Issue: Capital formation H.R. 7130 - McCarran-Ferguson Restoration Act. The bill would eliminate the Federal Insurance Office of the Department of the Treasury and establish a United States Insurance Representative within the Department of the Treasury. Issue: FIO Reform.

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

H.R.292 - To amend the Federal Crop Insurance Act to require the Federal Crop Insurance Corporation to carry out research and development regarding a policy to insure table, wine, and juice grapes against losses due to a freeze event, and for other purposes. H.R.550 - To require the Government Accountability Office to conduct a study regarding insurance coverage for damages from wildfires, and for other purposes. H.R.643 - To eliminate the Federal Insurance Office of the Department of the Treasury, and for other purposes. H.R.827 - To ensure the availability and affordability of homeowners' insurance coverage for catastrophic events. H.R.1481 - To amend the Internal Revenue Code of 1986 to establish a system for the taxation of catastrophic risk transfer companies to ensure sufficient capital to cover catastrophic insurance losses, and for other purposes. H.R.2123 - To amend the National Flood Insurance Act of 1968 to reauthorize the National Flood Insurance Program. S.586 - A bill to amend the Internal Revenue Code of 1986 to provide an advance refundable credit to offset certain flood insurance premiums, and for other purposes. S.824 - A bill to reauthorize the National Flood Insurance Program. H.R.2547 - To amend the Internal Revenue Code of 1986 to exclude debt held by certain insurance companies from capital assets and to extend capital loss carryovers for such companies from 5 years to 10 years. H.R.2567 - To amend the Internal Revenue Code of 1986 to provide special rules for purposes of determining if financial guaranty insurance companies are qualifying insurance corporations under the passive foreign investment company rules. H.R.2822 - To extend the National Flood Insurance Program through December 31, 2026. H.R.3437 - To prohibit the Federal Insurance Office of the Department of the Treasury and other financial regulators from collecting data directly from an insurance company. H.R.3664 - To prohibit private passenger automobile insurers from using certain income proxies to determine insurance rates and eligibility. H.R.3800 - To amend the National Flood Insurance Act of 1968 to prohibit the deferral of the issuance of letters of map revision based on the placement of fill or conditional letters of map revision based on the placement of fill, and for other purposes. H.R.2774 - To amend section 5 of the Flood Control Act of 1941 to impose a deadline for initiating the repair or restoration of project under such section, and for other purposes. H.R.3300 - To amend the Federal Water Pollution Control Act to clarify that a permit is not required under the National Pollutant Discharge Elimination System for a discharge resulting from the aerial application of certain products used for fire control and suppression, and for other purposes. S.1271 - A bill to amend the Federal Agriculture Improvement and Reform Act of 1996 with respect to transitioning producers from the noninsured crop assistance program to the whole farm revenue insurance plan. S.2053 - A bill to ensure that Write Your Own companies can sell private flood insurance products that compete with National Flood Insurance Program products. S.2054 - A bill to allow National Flood Insurance Program policyholders who leave the program to purchase a private insurance flood policy to return to the National Flood Insurance Program without penalty, and for other purposes. S.1437 - A bill to require the Administrator of the National Aeronautics and Space Administration to establish a program to identify, evaluate, acquire, and disseminate commercial Earth remote sensing data and imagery in order to satisfy the scientific, operational, and educational requirements of the Administration, and for other purposes. H.R.5574 - To extend the National Flood Insurance Program through November 21, 2025. H.R.5577 - NFIP Extension Act of 2026 H.R.5607 - Flood Insurance Transparency Act of 2025 H.R.5608 - To ensure that Write Your Own companies can sell private flood insurance products that compete with National Flood Insurance Program products. H.R.5500 - To make administrative reforms to the National Flood Insurance Program to increase fairness and accuracy and protect the taxpayer from program fraud and abuse, and for other purposes. H.R.5503 - To require the Federal Emergency Management Agency to establish a Territorial Disaster Recovery Program to continuously identify, monitor, and address factors and capability gaps that hinder the execution and completion of recovery activities relating to major disasters by eligible entities located in the territories of the United States. H.R.5504 - To amend the Internal Revenue Code of 1986 to allow for a credit against tax for certain flood insurance expenses. H.R.5229 - To provide for improvements to National Flood Insurance Program rate maps, and for other purposes. H.R.4735 - Business of Insurance Regulatory Reform Act of 2025 H.R.4504 - To require the Secretary of the Treasury to establish a catastrophic property loss reinsurance program, and for other purposes. S.2931 - A bill to reauthorize the National Flood Insurance Program. S.2946 - A bill to reauthorize the National Flood Insurance Program. S.2349 - A bill to require the Secretary of the Treasury to establish a catastrophic property loss reinsurance program, and for other purposes. S.2419 - Business of Insurance Regulatory Reform Act of 2025 H.R.5697 - To adjust the effective date of any adjustment based on Consumer Price Index to rail passenger liability cap that occurs during calendar year 2026. H.R.5848 - NFIP Retroactive Renewal and Reauthorization Act H.R.5961 - To increase the availability of flood insurance for agricultural structures, and for other purposes. H.R.5990 - To require the Secretary of Housing and Urban Development to establish a pilot program to provide grants to implementing organizations to administer a whole-home repairs program for eligible homeowners and eligible landlords, and for other purposes. H.R.6086 - To provide for funding from the Aviation Insurance Revolving Fund to continue certain Federal Aviation Administration activities in the event of a Government shutdown, and for other purposes. H.R.6155 - Federal Carjacking Enforcement Act H.R.6256 - To amend the Homeowner Flood Insurance Affordability Act of 2014 to address ecosystem restoration projects, and for other purposes. H.R.6274 - To establish a Natural Disaster Risk Reinsurance Program, and for other purposes. H.R.6560 - To amend the National Flood Insurance Act of 1968 to provide for the automatic contingent extension of the National Flood Insurance Program, and for other purposes. H.R.6620 - To amend the National Flood Insurance Act of 1968 to allow for the consideration of private flood insurance for the purposes of applying continuous coverage requirements, and for other purposes. H.R.7130 - McCarran-Ferguson Restoration Act H.R.7246 - To establish the Climate Financial Risk Committee and Climate Financial Risk Advisory Committee on the Financial Stability Oversight Council. H.R.7355 - To provide for the disclosure and sharing of certain policy and claims information under the National Flood Insurance Program, and for other purposes. H.R.7462 - To amend the Federal Crop Insurance Act to direct the Secretary of Agriculture to use certain data sets when determining eligibility related to indemnity payments under the Hurricane Insurance Protection-Wind Index endorsement, and for other purposes. H.R.7862 - To amend the National Flood Insurance Act of 1968 to limit the application of the Endangered Species Act with respect to certain actions under the national flood insurance program, and for other purposes. S.3711 - A bill to establish the Climate Financial Risk Committee and Climate Financial Risk Advisory Committee on the Financial Stability Oversight Council. S.3843 - A bill to amend the Federal Crop Insurance Act to direct the Federal Crop Insurance Corporation to conduct research and development on frost or cold weather insurance, and for other purposes. S.4088 - A bill to amend the Federal Crop Insurance Act to improve education and risk management assistance, and for other purposes. S.4215 - A bill to amend the Federal Crop Insurance Act to reduce Federal spending on crop insurance, and for other purposes.

NFIP Reauthorization (generally); HR.2123/S.824 - NFIP Extension Act of 2025; HR.643 - Federal Insurance Office Elimination Act; FHFA Property Insurance Requirements; S.1545 - Repeatedly Flooded Communities Preparation Act; HR.3437/S.1544 - Insurance Data Protection Act; HR.4494/S.2313 - The Flood Insurance Relief Act; HR.4735/S.2419 - Business of Insurance Regulatory Reform Act; HR.5577 - NFIP Extension Act of 2026; HR.6620 - To amend the National Flood Insurance Act of 1958 with continuous coverage requirements; HR.7130 - The McCarran-Ferguson Restoration Act

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

Government targets: Federal Housing Finance Agency (FHFA), 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)

Support HR 4735/S 2419 Business of Insurance Regulatory Reform Act - keeps insurance regulated by the states and not by the Consumer Financial Protection Bureau or set by international bodies. Advocate to preserve consumer access to voluntary insurance protection products in legislative proposals redefining APR calculations. Advocate for privacy measures in line with GLBA and HIPAA as applied to financial services. Support HR 2441/S 1877 Improving Disclosure for Investors Act - to provide electronic delivery of SEC regulatory documents. Included in the INVEST Act. Support HR 1777/S 1561 SECURE Notarization Act - authorizes notaries to perform, and to establish minimum standards for electronic notarizations and remote notarizations. Support increased CDFI and MDI funding in FY 2026 & 2027 Appropriations. Support preservation of the CDFI Fund. Oppose the S. 3623/H.R. 7035, the Credit Card Competition Act, a bill that would reduce interchange fees on credit cards. Support the Retirement Fairness for Charities and Educational Institutions Act (HR 1013/S 424). Allows 403(b) retirement plans to invest in unregistered insurance contracts and CITs. Included in the INVEST Act. Support the TRAPs Act (Task Force for Recognizing and Averting Payment Scams) (HR 4936/S 2019) and other legislation that protects consumers from payment scams and fraud. Support S. 3940, the Access to Fair Financing for Opportunity and Resilient Development (AFFORD) Act, which brings together four CDFI bills that would support CDFI secondary markets and access to capital through the Bond Guarantee Program, among other improvements. Support the credit union tax exemption.

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

Support HR 4735/S 2419 Business of Insurance Regulatory Reform Act - keeps insurance regulated by the states and not by the Consumer Financial Protection Bureau or set by international bodies. Advocate to preserve consumer access to voluntary insurance protection products in legislative proposals redefining APR calculations. Advocate for privacy measures in line with GLBA and HIPAA as applied to financial services. Monitor how federal AI legislation impacts insurers ability to conduct business. Monitor how federal stablecoin market structure legislation impacts insurers ability to conduct business.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. __ - State Regulation of Insurance Preservation Act. The bill would limit certain authorities and duties of the Federal Insurance Office of the Department of the Treasury. Issue: Federal Insurance Office. H.R. 4735 - Business of Insurance Regulatory Reform Act (To amend the Consumer Financial Protection Act of 2010 to clarify the authority of the Bureau of Consumer Financial Protection with respect to persons regulated by a State insurance regulator. Issue: Business of Insurance.) H.R. 643 FIO Elimination Act (This bill eliminates the Federal Insurance Office (FIO) within the Department of the Treasury. The bill also removes the FIO director as a nonvoting member of the Financial Stability Oversight Council.) H.R.3682 - Financial Stability Oversight Council Improvement Act of 2025 (FSOC nonbank guidance rule) S. 1544/H.R. 3437 - Insurance Data Protection Act. To prohibit the Federal Insurance Office of the Department of the Treasury and other financial regulators from collecting data directly from an insurance company. Issue: FIO Reform

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

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

Support HR 4735/S 2419 Business of Insurance Regulatory Reform Act - keeps insurance regulated by the states and not by the Consumer Financial Protection Bureau or set by international bodies. Advocate for privacy measures in line with GLBA and HIPAA as applied to financial services. Monitor how federal AI legislation impacts insurers' ability to conduct business. Monitor the impact of federal stablecoin legislation on insurers business operations. The GENIUS Act (S 1582) became law last quarter as Public Law 119-27, establishing a regulatory framework for stablecoins. The CLARITY Act (HR 3633), which addresses stablecoin marketplace structure, has passed the House and is currently awaiting Senate consideration.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Support HR 4735/S 2419 Business of Insurance Regulatory Reform Act - keeps insurance regulated by the states and not by the Consumer Financial Protection Bureau or set by international bodies. Advocate for privacy measures in line with GLBA and HIPAA as applied to financial services. Support HR 2441/S 1877 Improving Disclosure for Investors Act - to provide electronic delivery of SEC regulatory documents. Support HR 1777/S 1561 SECURE Notarization Act - authorizes notaries to perform, and to establish minimum standards for, electronic notarizations and remote notarizations. Support increased CDFI and MDI funding in FY 2026 Appropriations. Oppose the Credit Card Competition Act, a bill that would reduce interchange fees on credit cards, when reintroduced. Support the Retirement Fairness for Charities and Educational Institutions Act (HR 1013/S 424). Allows 403(b) retirement plans to invest in unregistered insurance contracts and CITs. Support the TRAPs Act (Task Force for Recognizing and Averting Payment Scams) (HR 4936/S 2019) and other legislation that protects consumers from payment scams and fraud.

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

H.R.292 - To amend the Federal Crop Insurance Act to require the Federal Crop Insurance Corporation to carry out research and development regarding a policy to insure table, wine, and juice grapes against losses due to a freeze event, and for other purposes. H.R.550 - To require the Government Accountability Office to conduct a study regarding insurance coverage for damages from wildfires, and for other purposes. H.R.643 - To eliminate the Federal Insurance Office of the Department of the Treasury, and for other purposes. H.R.827 - To ensure the availability and affordability of homeowners' insurance coverage for catastrophic events. H.R.1481 - To amend the Internal Revenue Code of 1986 to establish a system for the taxation of catastrophic risk transfer companies to ensure sufficient capital to cover catastrophic insurance losses, and for other purposes. H.R.2123 - To amend the National Flood Insurance Act of 1968 to reauthorize the National Flood Insurance Program. S.586 - A bill to amend the Internal Revenue Code of 1986 to provide an advance refundable credit to offset certain flood insurance premiums, and for other purposes. S.824 - A bill to reauthorize the National Flood Insurance Program. H.R.2547 - To amend the Internal Revenue Code of 1986 to exclude debt held by certain insurance companies from capital assets and to extend capital loss carryovers for such companies from 5 years to 10 years. H.R.2567 - To amend the Internal Revenue Code of 1986 to provide special rules for purposes of determining if financial guaranty insurance companies are qualifying insurance corporations under the passive foreign investment company rules. H.R.2822 - To extend the National Flood Insurance Program through December 31, 2026. H.R.3437 - To prohibit the Federal Insurance Office of the Department of the Treasury and other financial regulators from collecting data directly from an insurance company. H.R.3664 - To prohibit private passenger automobile insurers from using certain income proxies to determine insurance rates and eligibility. H.R.3800 - To amend the National Flood Insurance Act of 1968 to prohibit the deferral of the issuance of letters of map revision based on the placement of fill or conditional letters of map revision based on the placement of fill, and for other purposes. H.R.2774 - To amend section 5 of the Flood Control Act of 1941 to impose a deadline for initiating the repair or restoration of project under such section, and for other purposes. H.R.3300 - To amend the Federal Water Pollution Control Act to clarify that a permit is not required under the National Pollutant Discharge Elimination System for a discharge resulting from the aerial application of certain products used for fire control and suppression, and for other purposes. S.1271 - A bill to amend the Federal Agriculture Improvement and Reform Act of 1996 with respect to transitioning producers from the noninsured crop assistance program to the whole farm revenue insurance plan. S.2053 - A bill to ensure that Write Your Own companies can sell private flood insurance products that compete with National Flood Insurance Program products. S.2054 - A bill to allow National Flood Insurance Program policyholders who leave the program to purchase a private insurance flood policy to return to the National Flood Insurance Program without penalty, and for other purposes. S.1437 - A bill to require the Administrator of the National Aeronautics and Space Administration to establish a program to identify, evaluate, acquire, and disseminate commercial Earth remote sensing data and imagery in order to satisfy the scientific, operational, and educational requirements of the Administration, and for other purposes. H.R.5574 - To extend the National Flood Insurance Program through November 21, 2025. H.R.5577 - NFIP Extension Act of 2026 H.R.5607 - Flood Insurance Transparency Act of 2025 H.R.5608 - To ensure that Write Your Own companies can sell private flood insurance products that compete with National Flood Insurance Program products. H.R.5500 - To make administrative reforms to the National Flood Insurance Program to increase fairness and accuracy and protect the taxpayer from program fraud and abuse, and for other purposes. H.R.5503 - To require the Federal Emergency Management Agency to establish a Territorial Disaster Recovery Program to continuously identify, monitor, and address factors and capability gaps that hinder the execution and completion of recovery activities relating to major disasters by eligible entities located in the territories of the United States. H.R.5504 - To amend the Internal Revenue Code of 1986 to allow for a credit against tax for certain flood insurance expenses. H.R.5229 - To provide for improvements to National Flood Insurance Program rate maps, and for other purposes. H.R.4735 - Business of Insurance Regulatory Reform Act of 2025 H.R.4504 - To require the Secretary of the Treasury to establish a catastrophic property loss reinsurance program, and for other purposes. S.2931 - A bill to reauthorize the National Flood Insurance Program. S.2946 - A bill to reauthorize the National Flood Insurance Program. S.2349 - A bill to require the Secretary of the Treasury to establish a catastrophic property loss reinsurance program, and for other purposes. S.2419 - Business of Insurance Regulatory Reform Act of 2025 H.R.5697 - To adjust the effective date of any adjustment based on Consumer Price Index to rail passenger liability cap that occurs during calendar year 2026. H.R.5848 - NFIP Retroactive Renewal and Reauthorization Act H.R.5961 - To increase the availability of flood insurance for agricultural structures, and for other purposes. H.R.5990 - To require the Secretary of Housing and Urban Development to establish a pilot program to provide grants to implementing organizations to administer a whole-home repairs program for eligible homeowners and eligible landlords, and for other purposes. H.R.6086 - To provide for funding from the Aviation Insurance Revolving Fund to continue certain Federal Aviation Administration activities in the event of a Government shutdown, and for other purposes. H.R.6155 - Federal Carjacking Enforcement Act H.R.6256 - To amend the Homeowner Flood Insurance Affordability Act of 2014 to address ecosystem restoration projects, and for other purposes. H.R.6274 - To establish a Natural Disaster Risk Reinsurance Program, and for other purposes. H.R.6560 - To amend the National Flood Insurance Act of 1968 to provide for the automatic contingent extension of the National Flood Insurance Program, and for other purposes. H.R.6620 - To amend the National Flood Insurance Act of 1968 to allow for the consideration of private flood insurance for the purposes of applying continuous coverage requirements, and for other purposes.

NFIP Reauthorization (generally); HR.2123/S.824 - NFIP Extension Act of 2025; HR.643 - Federal Insurance Office Elimination Act; FHFA Property Insurance Requirements; S.1545 - Repeatedly Flooded Communities Preparation Act; HR.3437/S.1544 - Insurance Data Protection Act; HR.4494/S.2313 - The Flood Insurance Relief Act; HR.4735/S.2419 - Business of Insurance Regulatory Reform Act; HR.5577 - NFIP Extension Act of 2026; HR.6620 - To amend the National Flood Insurance Act of 1958 with continuous coverage requirements

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

Government targets: Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, SENATE

Protect the credit union tax exemption Support legislation and regulation that advance credit unions and their over 144 million members Support regulatory relief for credit unions Support holistic evaluation of regulatory burden on credit unions Support credit union field of membership expansion and modernization Support regulator- and bank-approved credit union-bank mergers Support financial inclusion and increased access to financial services Support modifying the credit union member business lending cap Support NCUAs existence as an independent regulator and insurer of credit unions Support assistance for minority depository institution credit unions Support regulatory relief for de novo credit unions Support harmonization of federal cyber incident notification standards Oppose Community Reinvestment Act requirements for credit unions Oppose legislative action to restrict credit union overdraft and courtesy pay programs Support regulatory framework for artificial intelligence that allows responsible innovation and recognizes credit unions compliance with existing regulations Support allowing use of artificial intelligence for regulatory reporting purposes Support mandatory arbitration agreements Oppose national interest rate cap Support Federal Credit Union Act modernization Support expanded natural person and corporate credit union investment authority Support expanded credit union examination cycle Support increased examination transparency Support Central Liquidity Facility and Community Development Revolving Loan Fund enhancements Oppose NCUA examination of credit union vendors Support modification of credit union loan maturity limits Oppose National Credit Union Share Insurance Fund structural changes Oppose National Credit Union Share Insurance Fund premium assessment Support parity in deposit insurance coverage levels between credit unions and banks Oppose additional Call Report fields on loans to credit union officials and senior executive staff Oppose additional Call Report fields on maturity distribution of uninsured shares Oppose making changes to Call Report requirements without using notice-and-comment process Oppose NCUA Call Report collection of overdraft and NSF fee revenue data Support modernization and simplification of Call Report form and instructions Support rescission of NCUA overdraft and NSF fee guidance Oppose collection of vendor information in NCUA Credit Union Profile Oppose changes to NCUA collection forms outside rulemaking process Support NCUA review of normal operating level and methodology Support NCUA action to permit credit union reimbursement of childcare expenses for federal credit union board meetings Oppose NCUA acting as a climate regulator Oppose NCUA rule on succession planning Oppose NCUA rule on record retention Oppose excessive NCUA requirements for supervisory committee audits Support NCUA recognition of digital banking in service facility definition Support clarification of NCUA member expulsion regulations Support NCUA proposed rule on increasing overdraft flexibility Support NCUA recognition of government sponsored enterprises as government agencies for loan maturity limit purposes Support NCUA adoption of floating interest rate cap Support modification of NCUA commercial loan definition Support increased flexibility in NCUA occupancy requirements Support NCUA action to clarify loan participation limits Support NCUA modification of low-income designation process Support expanding NCUA qualified charity definition Support allowing greater weighted average life for corporate credit unions financial assets Support extension of maturity limit for corporate credit union borrowing Support NCUA action to reduce scope of supervisory committee examination Support NCUA adopting limited retention period for operational records Support increased flexibility for advertising and notice of insured status Oppose proposed incentive-based compensation rule Support increased compliance timeline for NCUA simplification of share insurance rule Support removing reputational risk as a component of credit union examinations Support balanced implementation of debanking executive order Support increased NCUA efforts to promote credit union industry Support modernization and streamlining of NCUA operations Support NCUA supervisory flexibility for credit union shutdown assistance efforts Support NCUA action to modernize CAMELS rating system Support modernization of NCUA fidelity bond review requirements Support making CFPB subject to regular appropriations process Support increased CFPB budget transparency Support restructuring CFPB leadership to a bipartisan commission Support creation of a CFPB Inspector General Support reforms to CFPB Civil Investigative Demand process Support increasing asset thresholds for CFPB supervision of credit unions Support clarification of CFPB unfair, deceptive, or abusive acts and practices authority Support CFPB use of Section 1022 authority to exempt credit unions from certain regulations Support CFPB oversight and monitoring of nonbank entities Oppose CFPB efforts to avoid requirements of the rulemaking process Support CFPB use and disclosure of relevant data in rulemakings Support CFPB use of cost-benefit analysis in rulemaking process Support CFPB policies to promote innovation and access to credit Support CFPB coordination with NCUA on policy matters and examination scheduling Oppose mislabeling financial services fees as junk fees Oppose arbitrary limits on credit union fee income Oppose CFPB efforts to restrict information in credit reports Oppose CFPB efforts to manipulate consumer complaint data Support CFPB engaging in ongoing retrospective review of past regulations Support CFPB consumer complaint database reforms Support CFPB no-action letter program with extended timeline and increased protection of sensitive strategic information Oppose CFPB action to prohibit use of certain contractual terms and conditions Oppose expansion of consumer report and consumer reporting agency definitions under the Fair Credit Reporting Act/Regulation V Support consumer protection regulations for buy-now-pay-later loan providers Support inclusion of buy-now-pay-later loans in FHA underwriting Support CFPB use of Civil Penalty Fund for consumer financial education Support increase of Home Mortgage Disclosure Act reporting thresholds Support removal of disparate impact analysis from Regulation B and modification of discouragement standard Support credit union access to universal service fund letters of credit program Support recognition of unique credit union structure in Financial Data Transparency Act joint data standards Support federal data privacy and security standard that exempts Gramm-Leach-Bliley Act covered institutions, preempts state laws, operates on an opt-out basis, recognizes the complexity of data deletion, and does not authorize private right of action Support increased transparency for fintech bank charter applications Support Treasury development of model forms and qualified vehicle list for auto loan interest deduction Support safe harbor for credit unions related to the auto loan interest deduction Support clarification of remittance transfer tax exemptions Support inclusion of credit unions in Trump Accounts program Oppose development of a central bank digital currency Support credit union access to Federal Reserve liquidity options Support gradual expansion of Fedwire and National Settlement Service operating hours with optional participation Oppose addition of fourth same-day ACH window Support expanded flexibility for accessing the Fed discount window and intraday credit Oppose expanded eligibility for Federal Reserve master account access Oppose Regulation II debit interchange fee cap Oppose Federal Reserve proposed rule on modifying Regulation II debit interchange cap Support improvements to the Federal Reserves Debit Card Issuer Survey Oppose legislative action to impose caps or restrictions on debit or credit interchange fees Oppose legislative action to prohibit the Federal Reserve from paying interest on reserves Support Federal Reserve action to coordinate regulatory guidance on penny circulation issues and management of penny supply Oppose expansion of Electronic Fund Transfer Act/Regulation E financial institution liability Support fair distribution of Electronic Fund Transfer Act/Regulation E error resolution responsibilities Oppose Electronic Fund Transfer Act/Regulation E liability for financial institutions for consumer-authorized transactions Support clarification of funds definition under Electronic Fund Transfer Act/Regulation E Support clarification of Electronic Fund Transfer Act/Regulation E treatment of digital assets Support increased flexibility for check holds and funds availability requirements Support transition to electronic payments for government payments Support consumer education on transition to electronic payments Support clarification of information sharing safe harbor for identifying and preventing payments fraud Support greater flexibility for credit unions to decline services with clear indica of fraud or elder abuse Support parity for credit union provision of digital asset services Prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products Support Treasury and NCUA action to implement regulatory framework for stablecoin issuance Support parity for credit unions related to stablecoin regulation Support NCUAs role as primary regulator of credit unions stablecoin activities Oppose treating stablecoins or digital assets as federally insured Support digital assets guardrails to prevent deposit outflows Support clarifying credit unions authority to provide custodial services for their members Support safeguards for rehypothecation of digital assets Support reduced government-sponsored enterprises costs for credit union mortgages Support secondary mortgage market access for credit unions Support continued role for FHFA as an independent regulator Support credit union access to Federal Home Loan Bank system Support expansion of Federal Home Loan Bank Act community financial institution definition Support Federal Home Loan Bank engagement with credit unions Oppose adoption of volume-based incentives for Federal Home Loan Banks Oppose policy changes to limit access to Federal Home Loan Bank liquidity Support Federal Home Loan Bank allocations to the Affordable Housing Program Support FinCEN implementation of the Corporate Transparency Act Support additional time to implement anti-money laundering/countering financing of terrorism program changes and publication of guidance Support increasing Currency Transaction Report and Suspicious Activity Report filing thresholds Support streamlining Currency Transaction Report and Suspicious Activity Report forms Support increased inclusion of identifiable information in Section 314(a) information requests Support consistency between NCUA and FinCEN requirements on Bank Secrecy Act compliance Support FinCEN survey to accurately measure Bank Secrecy Act compliance costs Support DOD clarification of Military Lending Act and Servicemembers Civil Relief Act requirements Support standardized disclosures and financial literacy briefings for servicemembers Support credit union access to nominal leases on military installations Oppose nominal leases for banks on military installations Oppose legislative action on the Overseas Military Banking Program Oppose inclusion of interchange or interest rate cap amendments in the National Defense Authorization Act Support federal share insurance for all credit unions acting as fiscal agents of the U.S. government Support role of Community Development Financial Institutions Fund in promoting economic growth and access to capital in underserved communities Support access to Community Development Financial Institutions Fund awards and technical assistance for credit unions Support Community Development Financial Institutions Fund bond guarantee program Support Community Development Financial Institutions Fund liquidity enhancement pilot program Support disbursement of all Community Development Financial Institution Fund appropriated award funding Support timely completion of Emergency Capital Investment Program disposition agreements Oppose CFPB rulemaking on contract terms and conditions Oppose reclassification of credit header information as a consumer report Oppose reliance on single source of documentation to determine instances of identity theft or coerced debt Oppose use of interim final rule to modify personal financial data rights requirements Support modification of Section 1033 rule to allow data providers to charge fees, remove prescriptive technology standards, and establish data privacy standards and allocation of liability Support increased reporting and small business revenue threshold and elimination of discretionary data points collection in revised Section 1071 rule Support modernization of e-signature requirements Support allowing electronic or documented oral credit card applications Support increased flexibility for disclosures Support rescission of CFPB payday lending rule payment provisions Support modification of FCC revocation of consent rule Support greater flexibility for FCC fraud alert exemption Support uniform federal standards and increased federal preemption of state laws on interchange, data privacy, artificial intelligence, and elder financial abuse reporting Issues related to housing finance reform Issues related to flood insurance Issues related to privately insured credit unions Issues related to credit union capital requirements Issues related to credit union conversions Issues related to credit unions as employers Issues related to the Foreign Account Tax Compliance Act Issues related to fair lending Issues related to the Telephone Consumer Protection Act Support Credit Union Board Modernization Act (H.R. 975; S. 522) Support 1071 Repeal to Protect Small Business Lending Act (H.R. 976; S. 557) Support Making the CFPB Accountable to Small Businesses Act (H.R. 1606) Support Financial Integrity and Regulation Management Act (S. 875; H.R. 2702; Senate Amendment 3104) Support Fair Audits and Inspections for Regulators Act (H.R. 940) Support Anti-CBDC Surveillance State Act (H.R. 1919; S. 1124) Support Veterans Member Business Loan Act (H.R. 507; S. 110; Senate Amendment 3776) Support Taking Account of Bureaucrats Spending Act (H.R. 654) Support Rectifying UDAAP Act (H.R. 1652) Support Civil Investigative Demand Reform Act (H.R. 1653) Support SECURE Notarization Act (H.R. 1777; S. 1561) Support Increasing Credit Union Lending for Business Growth Act (H.R. 1791) Support Financial Reporting Threshold Modernization Act (H.R. 1799; Amendment 715 to H.R. 3838) Support Home of Your Own Act (H.R. 2064) Support Homes for Every Local Protector, Educator, and Responder Act (H.R. 2094; S. 978) Support CFPB Dual Mandate and Economic Analysis Act (H.R. 2183) Support Transparency in CFPB Cost-Benefit Analysis Act (H.R. 2331) Support CFPB-IG Reform Act (H.R. 2513) Support Homebuyers Privacy Protection Act (H.R. 2808; S. 1467) Support Financial Institution Regulatory Tailoring Enhancement Act (H.R. 3230) Support Halting Uncertain Methods and Practices in Supervision Act (H.R. 3379) Support Taking Account of Institutions with Low Operation Risk Act (H.R. 3380) Support Bureau of Consumer Financial Protection Commission Act (H.R. 3445) Support Expanding Access to Lending Options Act (H.R. 4167) Support CDFI Bond Guarantee Program Improvement Act (S. 1880) Support Taskforce for Recognizing and Averting Payment Scams Act (H.R. 4936; S. 2019; Senate Amendment 3257) Support Capping Excessive Awarding of SBLC Entrants Act (H.R. 2987) Support Expanding Access to Lending Options Act (H.R. 4167) Support Supervisory Modifications for Appropriate Risk-Based Testing Act (H.R. 4437) Support Stop Agency Fiat Enforcement Act (H.R. 4460) Support American Access to Banking Act (H.R. 4544) Support Protecting Access to Credit for Small Businesses Act (S. 2486) Support Business of Insurance Regulatory Reform Act (H.R. 4735; S. 2419) Support NCUA Central Liquidity Facility Enhancement Act (S. 2545; Senate Amendment 3722) Support CDFI Fund Transparency Act (S. 2704; Senate Amendments 3640, 3732) Support Supporting Upgraded Property Projects and Lending for Yards Act (H.R. 4568) Support Unleashing AI Innovation in Financial Services Act (H.R. 4801) Support AI Practices, Logistics, Actions, and Necessities Act (H.R. 2152) Support Streamlining Transaction Reporting and Ensuring Anti-Money Laundering Improvements for a New Era Act (S. 3017) Support NFIP Continuation Act (H.R. 5577) Support Housing for the 21st Century Act (H.R. 6644) Support Regulatory Efficiency, Verification, Itemization, and Enhanced Workflow Act (H.R. 6544) Support inclusion of guidance on penny circulation in Common Cents Act (H.R. 3074) Support parity for credit unions in Digital Asset Market Clarity Act (H.R. 3633) Support modification of Section 705 in Renewing Opportunity in the American Dream to Housing Act (S. 2651) Oppose 10 Percent Credit Card Interest Rate Cap Act (H.R. 1944; S. 381; Senate Amendment 2239) Oppose Credit Card Competition Act (Senate Amendments 2229, 2230, 2345) Oppose commissary interchange fee study (Senate Amendment 3216) Oppose End the Feds Big Bank Bailout Act (S. 2113; Senate Amendment 3761)

H.R.292 - To amend the Federal Crop Insurance Act to require the Federal Crop Insurance Corporation to carry out research and development regarding a policy to insure table, wine, and juice grapes against losses due to a freeze event, and for other purposes. H.R.550 - To require the Government Accountability Office to conduct a study regarding insurance coverage for damages from wildfires, and for other purposes. H.R.643 - To eliminate the Federal Insurance Office of the Department of the Treasury, and for other purposes. H.R.827 - To ensure the availability and affordability of homeowners' insurance coverage for catastrophic events. H.R.1481 - To amend the Internal Revenue Code of 1986 to establish a system for the taxation of catastrophic risk transfer companies to ensure sufficient capital to cover catastrophic insurance losses, and for other purposes. H.R.2123 - To amend the National Flood Insurance Act of 1968 to reauthorize the National Flood Insurance Program. S.586 - A bill to amend the Internal Revenue Code of 1986 to provide an advance refundable credit to offset certain flood insurance premiums, and for other purposes. S.824 - A bill to reauthorize the National Flood Insurance Program. H.R.2547 - To amend the Internal Revenue Code of 1986 to exclude debt held by certain insurance companies from capital assets and to extend capital loss carryovers for such companies from 5 years to 10 years. H.R.2567 - To amend the Internal Revenue Code of 1986 to provide special rules for purposes of determining if financial guaranty insurance companies are qualifying insurance corporations under the passive foreign investment company rules. H.R.2822 - To extend the National Flood Insurance Program through December 31, 2026. H.R.3437 - To prohibit the Federal Insurance Office of the Department of the Treasury and other financial regulators from collecting data directly from an insurance company. H.R.3664 - To prohibit private passenger automobile insurers from using certain income proxies to determine insurance rates and eligibility. H.R.3800 - To amend the National Flood Insurance Act of 1968 to prohibit the deferral of the issuance of letters of map revision based on the placement of fill or conditional letters of map revision based on the placement of fill, and for other purposes. H.R.2774 - To amend section 5 of the Flood Control Act of 1941 to impose a deadline for initiating the repair or restoration of project under such section, and for other purposes. H.R.3300 - To amend the Federal Water Pollution Control Act to clarify that a permit is not required under the National Pollutant Discharge Elimination System for a discharge resulting from the aerial application of certain products used for fire control and suppression, and for other purposes. S.1271 - A bill to amend the Federal Agriculture Improvement and Reform Act of 1996 with respect to transitioning producers from the noninsured crop assistance program to the whole farm revenue insurance plan. S.2053 - A bill to ensure that Write Your Own companies can sell private flood insurance products that compete with National Flood Insurance Program products. S.2054 - A bill to allow National Flood Insurance Program policyholders who leave the program to purchase a private insurance flood policy to return to the National Flood Insurance Program without penalty, and for other purposes. S.1437 - A bill to require the Administrator of the National Aeronautics and Space Administration to establish a program to identify, evaluate, acquire, and disseminate commercial Earth remote sensing data and imagery in order to satisfy the scientific, operational, and educational requirements of the Administration, and for other purposes. H.R.5574 - To extend the National Flood Insurance Program through November 21, 2025. H.R.5577 - NFIP Extension Act of 2026 H.R.5607 - Flood Insurance Transparency Act of 2025 H.R.5608 - To ensure that Write Your Own companies can sell private flood insurance products that compete with National Flood Insurance Program products. H.R.5500 - To make administrative reforms to the National Flood Insurance Program to increase fairness and accuracy and protect the taxpayer from program fraud and abuse, and for other purposes. H.R.5503 - To require the Federal Emergency Management Agency to establish a Territorial Disaster Recovery Program to continuously identify, monitor, and address factors and capability gaps that hinder the execution and completion of recovery activities relating to major disasters by eligible entities located in the territories of the United States. H.R.5504 - To amend the Internal Revenue Code of 1986 to allow for a credit against tax for certain flood insurance expenses. H.R.5229 - To provide for improvements to National Flood Insurance Program rate maps, and for other purposes. H.R.4735 - Business of Insurance Regulatory Reform Act of 2025 H.R.4504 - To require the Secretary of the Treasury to establish a catastrophic property loss reinsurance program, and for other purposes. S.2931 - A bill to reauthorize the National Flood Insurance Program. S.2946 - A bill to reauthorize the National Flood Insurance Program. S.2349 - A bill to require the Secretary of the Treasury to establish a catastrophic property loss reinsurance program, and for other purposes. S.2419 - Business of Insurance Regulatory Reform Act of 2025

NFIP Reauthorization (generally); HR.2123/S.824 - NFIP Extension Act of 2025; HR.643 - Federal Insurance Office Elimination Act; FHFA Property Insurance Requirements; S.1545 - Repeatedly Flooded Communities Preparation Act; HR.3437/S.1544 - Insurance Data Protection Act; HR.4494/S.2313 - The Flood Insurance Relief Act; HR.4735/S.2419 - Business of Insurance Regulatory Reform Act; HR.5577 - NFIP Extension Act of 2026

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

Government targets: Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, SENATE

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)

Support HR 4735/S 2419 Business of Insurance Regulatory Reform Act - keeps insurance regulated by the states and not by the Consumer Financial Protection Bureau or set by international bodies. Advocate for privacy measures in line with GLBA and HIPAA as applied to financial services. Monitor how federal AI legislation impacts insurers' ability to conduct business. Monitor the impact of federal stablecoin legislation on insurers business operations. The GENIUS Act (S 1582) became law last quarter as Public Law 119-27, establishing a regulatory framework for stablecoins. The CLARITY Act (HR 3633), which addresses stablecoin marketplace structure, has passed the House and is currently awaiting Senate consideration.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Support HR 4735/S 2419 Business of Insurance Regulatory Reform Act - keeps insurance regulated by the states and not by the Consumer Financial Protection Bureau or set by international bodies. Advocate for privacy measures in line with GLBA and HIPAA as applied to financial services. Support HR 2441/S 1877 Improving Disclosure for Investors Act - to provide electronic delivery of SEC regulatory documents. Support HR 1777/S 1561 SECURE Notarization Act - authorizes notaries to perform, and to establish minimum standards for, electronic notarizations and remote notarizations. Support increased CDFI and MDI funding in FY 2026 Appropriations. Oppose the Credit Card Competition Act, a bill that would reduce interchange fees on credit cards, when reintroduced. Support the Retirement Fairness for Charities and Educational Institutions Act (HR 1013/S 424). Allows 403(b) retirement plans to invest in unregistered insurance contracts and CITs. Support the TRAPs Act (Task Force for Recognizing and Averting Payment Scams) (HR 4936/S 2019) and other legislation that protects consumers from payment scams and fraud.

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