TRAPS Act

General discussions concerning payments, payment processing systems, small business payments, and fraud and scams; general update on transaction between Global Payments and Worldpay; discussions concerning PACE Act (H.R. 8395); discussions regarding the TRAPS Act (H.R. 4936/S. 2019); discussions concerning status of United States-Mexico-Canada Agreement; discussions concerning status of CLARITY Act/Digital Asset Market Clarity Act (H.R. 3633); general discussions regarding AI and agentic commerce, as well as the AI AGENT Act (S. 5051); discussion regarding Project Glasswing.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, White House Office

Issues related to financial services, fraud and risk management, payments, and technology. TRAPS Act (S 2019 and HR 4936), SCAM Act (HR 7548 and S.3774), National Strategy for Combating Scams Act (HR 6425), AI PLAN Act (HR 2152), GUARD Financial Data Act (HR 8398),

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to financial services, fraud and risk management, payments, and technology. TRAPS Act (S 2019 and HR 4936), SCAM Act (HR 7548 and S.3774), National Strategy for Combating Scams Act (HR 6425), AI PLAN Act (HR 2152), GUARD Financial Data Act (HR 8398),

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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

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

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

Lapses by the retail industry/merchants in securing consumer information continue to be extremely problematic and costly to consumers and financial institutions. MCUL is advocating that Congress hold retailers to the same or similar data security standard as the financial service industry has to abide by and require that retailers notify credit unions sooner once a breach occurs. We support the introduction and passage of legislation that ensures all businesses, institutions and organizations that collect, collect, use or share personal data subject to national standards, to include language that preempts state requirements, among other things. Credit Unions are fighting a significant surge in fraud/scams that is costing American consumers billions annually. MCUL is educating lawmakers on the impact fraud is having on members and on credit unions. Credit unions are supporting three fraud related bills currently: H.R. 9331, the Strengthening Transaction Oversight and Preventing (STOP) Payments Fraud Act; S.2019/H.R. 4936, the Task Force for Recognizing and Averting Payment Scams (TRAPS) Act; and S.3774/H.R. 7548, the Safeguarding Consumers from Advertizing Misconduct (SCAM) Act. We are urging our delegation to support the legislation and call on leadership to pass the bills. MCUL supports modernizing the Federal Credit Union Act (FCUA). The financial service industry is rapidly changing. Advancements in technology, including high speed internet connectivity, have significantly changed our society and how financial institutions do business. Updating the FCUA has become necessary to ensure federally chartered credit unions have the powers and flexibility to be competitive and members can benefit from new technology. We are currently supporting the Veterans Member Business Loan Act (S.210/H.R. 507) that would exempt credit union business loans to veterans from the member business lending cap and we are supporting the Credit Union Board Modernization Act (S.522/H.R. 975) which would afford federal credit unions flexibility with regard to how often their boards meet. MCUL is monitoring developments for GSE/housing finance reform and will advocate to make sure any reforms reflect the significant role credit unions play in the secondary mortgage market and we will defend against anything that is potentially harmful to credit unions and their members. MCUL is calling on Congress to pass bank secrecy act/anti-money laundering reforms and provide financial institutions relief from unnecessary, duplicate and burdensome rules and increase the SAR and CTR thresholds. MCUL is urging lawmakers in the House to co-sponsor and support H.R. 1799, the Financial Reporting Threshold Modernization Act which would increase the CTR threshold from $10k to $30k and index it going forward for inflation. It would also increase the SAR threshold from $5k to $10k. MCUL is educating members of our congressional delegation on the growing interest among credit union members and credit unions in cryptocurrency. We believe Congress should explore ways to regulate the delivery of financial services using digital currencies to ensure consumers are protected in the same way if they received financial services a financial institution. We urge Congress to look for ways to enable credit unions and other financial institutions to provide digital assets, so that these services can be properly overseen by federal regulators. Finally, credit unions seek parity with other financial institutions in this area as credit unions must be able to offer digital/crypto products and services directly to their members in the same way that other institutions can to their customers. Lastly, credit unions are non-for-profit member-owned financial institutions. Credit unions' consumer-focused model is self-regulating and a principal reason why credit unions are not covered by the Community Reinvestment Act (CRA). MCUL will educate members of the delegation of the work credit unions are doing to serve low/moderate-income, diverse communities and the negative impacts of including credit unions in the CRA. We will oppose efforts that would result in credit unions of any size being included in the CRA.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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

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

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

Digital assets, mobile payments, fraud, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy. FinCEN, Harmonizing CIP products; Digital assets, mobile payments, fraud, payment scams, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy. - S. 2019 TRAPS Act, HR 4936 TRAPS Act - S. 2983 Extending Expired Cybersecurity Authorities - HR 5079 Widespread Information Management for the Welfare of Infrastructure and Government Act

Client expense: $550,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), HOUSE OF REPRESENTATIVES, SENATE

Digital assets, mobile payments, fraud, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy. FinCEN, Harmonizing CIP products; Digital assets, mobile payments, fraud, payment scams, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, currency production/circulation and elimination of the penny, cyber-security, financial services, merchant cash advances, privacy. - S. 2019 TRAPS Act, HR 4936 TRAPS Act - S. 2983 Extending Expired Cybersecurity Authorities - HR 5079 Widespread Information Management for the Welfare of Infrastructure and Government Act - HR 3074 Common Cents Act

Client expense: $550,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

Discussions concerning status of United States-Mexico-Canada Agreement; discussions concerning status of the CLARITY Act (H.R.3633); discussions concerning the PACE Act (H.R.8395); discussions concerning Executive Order 14247, "Modernizing Payments to and from America's Bank Account"; discussions concerning the TRAPS Act (H.R.4936); general discussions concerning payments, payment processing systems, small business payments and payments fraud; general update on transaction between Global Payments and Worldpay.

Client expense: $200,000 · Firm income: Not reported

Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Small Business Administration (SBA)

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

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

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

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.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to financial services, fraud and risk management, payments, and technology. TRAPS Act (S 2019 and HR 4936), SCAM Act (HR 7548 and S.3774), National Strategy for Combating Scams Act (HR 6425), Foreign Robocall Elimination Act (S 2666), AI PLAN Act (HR 2152), FCRA Liability Harmonization Act (HR 2359), GUARD Financial Data Act (HR 8398), ReportScams.Gov Act (S 4782)

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to financial services, fraud and risk management, payments, and technology. TRAPS Act (S 2019 and HR 4936), SCAM Act (HR 7548 and S.3774), National Strategy for Combating Scams Act (HR 6425), Foreign Robocall Elimination Act (S 2666), AI PLAN Act (HR 2152), FCRA Liability Harmonization Act (HR 2359), GUARD Financial Data Act (HR 8398), ReportScams.Gov Act (S 4782)

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

Government targets: HOUSE OF REPRESENTATIVES, Office of the Vice President of the United States, SENATE

Digital assets, mobile payments, fraud, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy. FinCEN, Harmonizing CIP products; Digital assets, mobile payments, fraud, payment scams, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, currency production/circulation and elimination of the penny, cyber-security, financial services, merchant cash advances, privacy. - S. 2019 TRAPS Act, HR 4936 TRAPS Act - S. 2983 Extending Expired Cybersecurity Authorities - HR 5079 Widespread Information Management for the Welfare of Infrastructure and Government Act - HR 3074 Common Cents Act

Client expense: $550,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Office of Science & Technology Policy (OSTP), SENATE, Treasury, Dept of

Digital assets, mobile payments, fraud, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy. FinCEN, Harmonizing CIP products; Digital assets, mobile payments, fraud, payment scams, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy. - S. 2019 TRAPS Act, HR 4936 TRAPS Act - S. 2983 Extending Expired Cybersecurity Authorities - HR 5079 Widespread Information Management for the Welfare of Infrastructure and Government Act

Client expense: $550,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), HOUSE OF REPRESENTATIVES, SENATE

S. 4055/H.R. 1469, the Senior Security Act. S.4092, the No Crypto in Social Security Act. H.R. 6644, the ROAD to Housing Act. S. 2117/H.R. 1734, the Preventing Deep Fake Scams Act. S. 2840/H.R. 2478, the Financial Exploitation Prevention Act. S. 1467/H.R. 2808, the Homebuyers Privacy Protection Act. H.R. 2978, the GUARD Act. S. 4144/H.R. 306, the Ending Scam Credit Repair Act (ESCRA) Act. S.1773/H.R. 3469, the Tax Relief for Victims of Crimes, Scams, and Disasters Act. S. 2019/H.R. 4936, the Taskforce for Recognizing and Averting Payment Scams (TRAPS) Act. H.R. 3633, the Digital Asset Market Clarity Act. H.R. 6425, the National Strategy for Combating Scams Act. H.R. 7215, the Stop SCAMS Act. S.1877/H.R.2441, the Improving Disclosure for Investors Act. H.R.2988, the Protecting Prudent Investment of Retirement Savings Act. S. 1699, Artificial Intelligence Public Awareness and Education Campaign Act. No bill number. Discussed accredited investor issues. No bill number. Discussed fiduciary obligations. No bill number. Discussed investor protections. No bill number. Discussed veterans and scams. No bill number. Discussed Social Security and crypto investments.

Client expense: $3,830,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC)

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

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

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

Issues related to digital assets. H.R. 3633, the CLARITY Act Issues related to payments fraud & scams. S. 2019 and H.R.4936, the TRAPS Act Issues related to Artificial Intelligence, Payments, Payments processing systems, Data Privacy, Data Security, Cybersecurity, Fraud, Payments Modernization and Electronification

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

Government targets: Consumer Financial Protection Bureau (CFPB), HOUSE OF REPRESENTATIVES, SENATE

Issues related to financial services, fraud and risk management, payments, and technology. TRAPS Act (S 2019 and HR 4936).

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

Government targets: Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

Issues related to financial services, fraud and risk management, payments, and technology. TRAPS Act (S 2019 and HR 4936).

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

Government targets: Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

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

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

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

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Digital assets, mobile payments, fraud, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy. FinCEN, Harmonizing CIP products; Digital assets, mobile payments, fraud, payment scams, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, currency production/circulation and elimination of the penny, cyber-security, financial services, merchant cash advances, privacy. - S. 2019 TRAPS Act, HR 4936 TRAPS Act - S. 2983 Extending Expired Cybersecurity Authorities - HR 5079 Widespread Information Management for the Welfare of Infrastructure and Government Act - HR 3074 Common Cents Act

Client expense: $550,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Office of Science & Technology Policy (OSTP), SENATE, Treasury, Dept of

Digital assets, mobile payments, fraud, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy. FinCEN, Harmonizing CIP products; Digital assets, mobile payments, fraud, payment scams, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy. - S. 2019 TRAPS Act, HR 4936 TRAPS Act - S. 2983 Extending Expired Cybersecurity Authorities - HR 5079 Widespread Information Management for the Welfare of Infrastructure and Government Act

Client expense: $550,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), HOUSE OF REPRESENTATIVES, SENATE

Issues related to digital assets. H.R. 3633, the CLARITY Act Issues related to payments fraud & scams. S. 2019 and H.R.4936, the TRAPS Act Issues related to Artificial Intelligence, Payments, Payments processing systems, Data Privacy, Data Security, Cybersecurity, Fraud, Payments Modernization and Electronification

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

Government targets: General Services Administration (GSA), HOUSE OF REPRESENTATIVES, SENATE, White House Office

H.R.2988, the Protecting Prudent Investment of Retirement Savings Act of 2025. H.R.2441, the Improving Disclosure for Investors Act of 2025. S.1877, the Improving Disclosure for Investors Act of 2025. H.R. 2478, the Financial Exploitation Prevention Act of 2025. H.R. 1734, the Preventing Deep Fake Scams Act of 2025. H.R. 4936/ S. 2019, the TRAPS Act of 2025. H.R. 2978, the GUARD Act of 2025. H.R. 1469, the Senior Security Act of 2025. H.R. 3469, the Tax Relief for Victims of Crimes, Scams, and Disasters Act of 2025. S. 1699Artificial Intelligence Public Awareness and Education Campaign Act of 2025. S.2840Financial Exploitation Prevention Act of 2025. No bill number. Discussed accredited investor issues. No bill number. Discussed fiduciary obligations. No bill number. Discussed investor protections.

Client expense: $5,300,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC)

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to financial services, fraud and risk management, payments, and technology. TRAPS Act (S 2019 and HR 4936).

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

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

Issues related to financial services, fraud and risk management, payments, and technology. TRAPS Act (S 2019 and HR 4936).

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

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

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

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

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

Digital assets, mobile payments, fraud, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy. FinCEN, Harmonizing CIP products; Digital assets, mobile payments, fraud, payment scams, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy. - S. 2019 TRAPS Act, HR 4936 TRAPS Act - S. 2983 Extending Expired Cybersecurity Authorities - HR 5079 Widespread Information Management for the Welfare of Infrastructure and Government Act -

Client expense: $550,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Office of Science & Technology Policy (OSTP), SENATE, Treasury, Dept of

Digital assets, mobile payments, fraud, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy. FinCEN, Harmonizing CIP products; Digital assets, mobile payments, fraud, payment scams, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy. - S. 2019 TRAPS Act, HR 4936 TRAPS Act - S. 2983 Extending Expired Cybersecurity Authorities - HR 5079 Widespread Information Management for the Welfare of Infrastructure and Government Act

Client expense: $550,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), HOUSE OF REPRESENTATIVES, SENATE

H.R. 4936 & S. 2019 the "TRAPS Act" aiding to combat payment scams targeting military families and veterans, Advocating for modernizing CTR & SAR reporting thresholds, Opposition to Marshall-Durbin Interchange and Commissary Amendments in NDAA

Client expense: $20,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 4936 & S. 2019 the "TRAPS Act" aiding to combat payment scams targeting military families and veterans, Advocating for modernizing CTR & SAR reporting thresholds, Opposition to Marshall-Durbin Interchange and Commissary Amendments in NDAA

Client expense: $20,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 4936 & S. 2019 the "TRAPS Act" aiding to combat payment scams targeting military families and veterans. General advocacy in support of the credit union's membership comprised of the military and veteran community and their families.

Client expense: $20,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 2544/H.R. 2978, the Guarding Unprotected Aging Retirees from Deception Act. H.R. 3523, the STOP Scammers Act. H.R. 306, the Ending Scam Credit Repair (ESCRA) Act. H.R. 2478/ S.2840, the Financial Exploitation Prevention Act of 2025. S. 1467/H.R. 2808, the Homebuyers Privacy Protection Act of 2025. S. 2117/H.R. 1734, the Preventing Deep Fake Scams Actof 2025. S. 2019/H.R. 4936, the Taskforce for Recognizing and Averting Payment Scams (TRAPS) Act of 2025. H.R. 1469, the Senior Security Act of 2025. H.R. 5490, the Dismantling Foreign Scam Syndicates Act of 2025. No bill number. Discussed the Accredited Investor Definition. No bill number. Discussed investor protections. No bill number. Discussed fraud protections.

Client expense: $3,810,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to digital assets. HR 2392, STABLE Act of 2025; S 394, GENIUS Act of 2025, H.R. 3633, the CLARITY Act Issues related to payments fraud. S. 2019 and H.R.4936, the TRAPS Act Issues related to Artificial Intelligence, Payments, Payments processing systems, Data Privacy, Data Security, Cybersecurity, Fraud, Payments Modernization and Electronification

Client expense: $100,000 · Firm income: Not reported

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

Protect the credit union tax exemption Support legislation and regulation that advance credit unions and their over 144 million members Support regulatory relief for credit unions Support holistic evaluation of regulatory burden on credit unions Support credit union field of membership expansion and modernization Support regulator- and bank-approved credit union-bank mergers Support financial inclusion and increased access to financial services Support modifying the credit union member business lending cap Support NCUAs existence as an independent regulator and insurer of credit unions Support assistance for minority depository institution credit unions Support regulatory relief for de novo credit unions Support harmonization of federal cyber incident notification standards Oppose Community Reinvestment Act requirements for credit unions Support regulatory framework for artificial intelligence that allows responsible innovation and recognizes compliance with existing regulations Support allowing use of artificial intelligence for regulatory reporting purposes Support mandatory arbitration agreements Oppose national interest rate cap Support Federal Credit Union Act modernization Support expanded natural person and corporate credit union investment authority Support expanded credit union examination cycle Support increased examination transparency Support Central Liquidity Facility enhancements Oppose NCUA examination of credit union vendors Support modification of credit union loan maturity limits Oppose National Credit Union Share Insurance Fund structural changes Oppose National Credit Union Share Insurance Fund premium assessment Support parity in deposit insurance coverage levels between credit unions and banks Oppose additional Call Report fields on loans to credit union officials and senior executive staff Oppose additional Call Report fields on maturity distribution of uninsured shares Oppose making changes to Call Report requirements without using notice-and-comment process Oppose NCUA Call Report collection of overdraft and NSF fee revenue data Support modernization and simplification of Call Report form and instructions Support rescission of NCUA overdraft and NSF fee guidance Oppose collection of vendor information in NCUA Credit Union Profile Oppose changes to NCUA collection forms outside rulemaking process Support NCUA review of normal operating level and methodology Support NCUA action to permit credit union reimbursement of childcare expenses for federal credit union board meetings Oppose NCUA acting as a climate regulator Oppose NCUA rule on succession planning Oppose NCUA rule on record retention Oppose excessive NCUA requirements for supervisory committee audits Support NCUA recognition of digital banking in service facility definition Support clarification of NCUA member expulsion regulations Support NCUA proposed rule on increasing overdraft flexibility Support NCUA recognition of government sponsored enterprises as government agencies for loan maturity limit purposes Support NCUA adoption of floating interest rate cap Support modification of NCUA commercial loan definition Support increased flexibility in NCUA occupancy requirements Support NCUA action to clarify loan participation limits Support NCUA modification of low-income designation process Support expanding NCUA qualified charity definition Support allowing greater weighted average life for corporate credit unions financial assets Support extension of maturity limit for corporate credit union borrowing Support NCUA action to reduce scope of supervisory committee examination Support NCUA adopting limited retention period for operational records Support increased flexibility for advertising and notice of insured status Oppose proposed incentive-based compensation rule Support increased compliance timeline for NCUA simplification of share insurance rule Support removing reputational risk as a component of credit union examinations Support balanced implementation of debanking executive order Support increased NCUA efforts to promote credit union industry Support modernization and streamlining of NCUA operations Support making CFPB subject to regular appropriations process Support increased CFPB budget transparency Support restructuring CFPB leadership to a bipartisan commission Support creation of a CFPB Inspector General Support reforms to CFPB Civil Investigative Demand process Support increasing asset thresholds for CFPB supervision of credit unions Support clarification of CFPB unfair, deceptive, or abusive acts and practices authority Support CFPB use of Section 1022 authority to exempt credit unions from certain regulations Support CFPB oversight and monitoring of nonbank entities Oppose CFPB efforts to avoid requirements of the rulemaking process Support CFPB use and disclosure of relevant data in rulemakings Support CFPB use of cost-benefit analysis in rulemaking process Support CFPB policies to promote innovation and access to credit Support CFPB coordination with NCUA on policy matters and examination scheduling Oppose mislabeling financial services fees as junk fees Oppose arbitrary limits on credit union fee income Support exemptions for CFPB Section 1071 final rule Oppose CFPB efforts to restrict information in credit reports Oppose CFPB Section 1071 final rule Oppose prohibition on use of medical debt information in credit decisions Oppose CFPB efforts to manipulate consumer complaint data Support CFPB engaging in ongoing retrospective review of past regulations Support CFPB consumer complaint database reforms Support CFPB no-action letter program with extended timeline and increased protection of sensitive strategic information Oppose CFPB action to prohibit use of certain contractual terms and conditions Oppose expansion of consumer report and consumer reporting agency under the Fair Credit Reporting Act/Regulation V Support consumer protection regulations for buy-now-pay-later loan providers Support inclusion of buy-now-pay-later loans in FHA underwriting Support CFPB use of Civil Penalty Fund for consumer financial education Support credit union access to universal service fund letters of credit program Support recognition of unique credit union structure in Financial Data Transparency Act joint data standards Support federal data privacy and security standard that exempts Gramm-Leach-Bliley Act covered institutions, preempts state laws, operates on an opt-out basis, recognizes the complexity of data deletion, and does not authorize private right of action Support increased transparency for fintech bank charter applications Support Treasury development of model forms and qualified vehicle list for auto loan interest deduction Support safe harbor for credit unions related to the auto loan interest deduction Oppose development of a central bank digital currency Support credit union access to Federal Reserve liquidity options Support gradual expansion of Fedwire and National Settlement Service operating hours with optional participation Oppose addition of fourth same-day ACH window Support expanded flexibility for accessing the Fed discount window and intraday credit Oppose expanded eligibility for Federal Reserve master account access Oppose Regulation II debit interchange fee cap Oppose Federal Reserve proposed rule on modifying Regulation II debit interchange cap Support improvements to the Federal Reserves Debit Card Issuer Survey Oppose legislative action to impose caps or restrictions on debit or credit interchange fees Oppose expansion of Electronic Fund Transfer Act/Regulation E financial institution liability Support fair distribution of Electronic Fund Transfer Act/Regulation E error resolution responsibilities Oppose Electronic Fund Transfer Act/Regulation E liability for financial institutions for consumer-authorized transactions Support clarification of funds definition under Electronic Fund Transfer Act/Regulation E Support clarification of Electronic Fund Transfer Act/Regulation E treatment of digital assets Support increased flexibility for check holds and funds availability requirements Support transition to electronic payments for government payments Support consumer education on transition to electronic payments Support clarification of information sharing safe harbor for identifying and preventing payments fraud Support greater flexibility for credit unions to decline services with clear indica of fraud or elder abuse Support parity for credit union provision of digital asset services Prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products Support parity for credit unions related to stablecoin regulation Support NCUAs role as primary regulator of credit unions stablecoin activities Oppose treating stablecoins or digital assets as federally insured Support digital assets guardrails to prevent deposit outflows Support clarifying credit unions authority to provide custodial services for their members Support safeguards for rehypothecation of digital assets Support reduced government-sponsored enterprises costs for credit union mortgages Support secondary mortgage market access for credit unions Support continued role for FHFA as an independent regulator Support credit union access to Federal Home Loan Bank system Support expansion of Federal Home Loan Bank Act community financial institution definition Support Federal Home Loan Bank engagement with credit unions Oppose adoption of volume-based incentives for Federal Home Loan Banks Oppose policy changes to limit access to Federal Home Loan Bank liquidity Support Federal Home Loan Bank allocations to the Affordable Housing Program Support FinCEN implementation of the Corporate Transparency Act Support additional time to implement anti-money laundering/countering financing of terrorism program changes and publication of guidance Support increasing Currency Transaction Report and Suspicious Activity Report filing thresholds Support streamlining Currency Transaction Report and Suspicious Activity Report forms Support consistency between NCUA and FinCEN requirements on Bank Secrecy Act compliance Support DOD clarification of Military Lending Act and Servicemembers Civil Relief Act requirements Support standardized disclosures and financial literacy briefings for servicemembers Support credit union access to nominal leases on military installations Oppose nominal leases for banks on military installations Oppose legislative action on the Overseas Military Banking Program Oppose inclusion of interchange or interest rate cap amendments in the National Defense Authorization Act Support federal share insurance for all credit unions acting as fiscal agents of the U.S. government Support role of Community Development Financial Institutions Fund in promoting economic growth and access to capital in underserved communities Support access to Community Development Financial Institutions Fund awards and technical assistance for credit unions Support Community Development Financial Institutions Fund bond guarantee program Support Community Development Financial Institutions Fund liquidity Enhancement pilot program Support disbursement of all Community Development Financial Institution Fund appropriated award funding Support timely completion of Emergency Capital Investment Program disposition agreements Oppose CFPB rulemaking on contract terms and conditions Oppose reclassification of credit header information as a consumer report Oppose reliance on single source of documentation to determine instances of identity theft or coerced debt Support enhanced transparency and consumer control of financial data Support modernization of e-signature requirements Support allowing electronic or documented oral credit card applications Support increased flexibility for disclosures Support rescission of CFPB payday lending rule payment provisions Support modification of FCC revocation of consent rule Support greater flexibility for FCC fraud alert exemption Support uniform federal standards and increased federal preemption of state laws on interchange, data privacy, artificial intelligence, and elder financial abuse reporting Issues related to housing finance reform Issues related to flood insurance Issues related to privately insured credit unions Issues related to credit union capital requirements Issues related to credit union conversions Issues related to credit unions as employers Issues related to the Foreign Account Tax Compliance Act Issues related to fair lending Issues related to the Telephone Consumer Protection Act Support Credit Union Board Modernization Act (H.R. 975; S. 522) Support 1071 Repeal to Protect Small Business Lending Act (H.R. 976; S. 557) Support Guiding and Establishing National Innovation for U.S. Stablecoins Act (S. 394, S. 919, S. 1582) Support Stablecoin Transparency and Accountability for a Better Ledger Economy Act (H.R. 2392) Support Making the CFPB Accountable to Small Businesses Act (H.R. 1606) Support Financial Integrity and Regulation Management Act (S. 875; H.R. 2702; Senate Amendment 3104) Support Fair Audits and Inspections for Regulators Act (H.R. 940) Support Anti-CBDC Surveillance State Act (H.R. 1919; S. 1124) Support Veterans Member Business Loan Act (H.R. 507; S. 110; Senate Amendment 3776) Support Taking Account of Bureaucrats Spending Act (H.R. 654) Support Rectifying UDAAP Act (H.R. 1652) Support Civil Investigative Demand Reform Act (H.R. 1653) Support SECURE Notarization Act (H.R. 1777; S. 1561) Support Increasing Credit Union Lending for Business Growth Act (H.R. 1791) Support Financial Reporting Threshold Modernization Act (H.R. 1799; Amendment 715 to H.R. 3838) Support Home of Your Own Act (H.R. 2064) Support Homes for Every Local Protector, Educator, and Responder Act (H.R. 2094; S. 978) Support CFPB Dual Mandate and Economic Analysis Act (H.R. 2183) Support Transparency in CFPB Cost-Benefit Analysis Act (H.R. 2331) Support CFPB-IG Reform Act (H.R. 2513) Support Homebuyers Privacy Protection Act (H.R. 2808; S. 1467) Support Financial Institution Regulatory Tailoring Enhancement Act (H.R. 3230) Support Halting Uncertain Methods and Practices in Supervision Act (H.R. 3379) Support Taking Account of Institutions with Low Operation Risk Act (H.R. 3380) Support Bureau of Consumer Financial Protection Commission Act (H.R. 3445) Support Expanding Access to Lending Options Act (H.R. 4167) Support CDFI Bond Guarantee Program Improvement Act (S. 1880) Support Taskforce for Recognizing and Averting Payment Scams Act (H.R. 4936; S. 2019; Senate Amendment 3257) Support Capping Excessive Awarding of SBLC Entrants Act (H.R. 2987) Support Expanding Access to Lending Options Act (H.R. 4167) Support Supervisory Modifications for Appropriate Risk-Based Testing Act (H.R. 4437) Support Stop Agency Fiat Enforcement Act (H.R. 4460) Support American Access to Banking Act (H.R. 4544) Support Protecting Access to Credit for Small Businesses Act (S. 2486) Support Business of Insurance Regulatory Reform Act (H.R. 4735; S. 2419) Support Renewing Opportunity in the American Dream to Housing Act (S. 2651) Support NCUA Central Liquidity Facility Enhancement Act (S. 2545; Senate Amendment 3722) Support CDFI Fund Transparency Act (S. 2704; Senate Amendments 3640, 3732) Support parity for credit unions in Digital Asset Market Clarity Act (H.R. 3633) Support changes to CFPB funding, creation of investment accounts for children, and auto loan interest deduction in H.R. 1 Oppose 10 Percent Credit Card Interest Rate Cap Act (H.R. 1944; S. 381; Senate Amendment 2239) Oppose Credit Card Competition Act (Senate Amendments 2229, 2230, 2345) Oppose commissary interchange fee study (Senate Amendment 3216)

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

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

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE