Community Bank LIFT Act

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

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

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

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

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

H.R. 478/S. 113, Promoting New Bank Formation Act S. 875/H.R. 2702, Financial Integrity and Regulation Management (FIRM) Act H.R. 1919/S. 1124, the Anti-CBDC Surveillance State Act H.R. 976/S. 557, the 1071 Repeal to Protect Small Business Lending Act H.R. 2392, the Stablecoin Transparency and Accountability for a Better Ledger Economy Act of 2025 (STABLE Act) S. 394/ S.919, Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS) Credit Card Competition Act H.R. 1944/S. 381, the 10 Percent Credit Card Interest Rate Cap Act H.R. 654, the Taking Account of Bureaucrats Spending (TABS) Act of 2025 H.R. 987/S. 401, the Fair Access to Banking Act H.R. 1652, the Rectifying UDAAP Act H.R. 3445, the Bureau of Consumer Financial Protection Commission Act H.R. 1653, the CID Reform Act Business of Insurance Regulatory Reform Act H.R. 2513, CFPB-IG Reform Act H.R. 2183, the CFPB Dual Mandate and Economic Analysis Act H.R. 2331, the Transparency in CFPB Cost-Benefit Analysis Act H.R. 1606, the Making the CFPB Accountable to Small Business Act Cybersecurity Information Sharing Act Community Development Financial Institutions (CDFI) Fund Secure and Fair Enforcement (SAFE) Banking Act Regulatory Tailoring Community Reinvestment Act Dodd-Frank Section 1033 Open Banking Rule Deposit Insurance Reform National Bank Preemption H.R. 306, the Ending Scam Credit Repair Act Bank On Certification Program Central Bank Digital Currency Cryptocurrency Stablecoin Digital Assets Bank Capital Requirements/Basel Capital Proposal UDAAP Supervisory Policies and Adjudication Procedures Applying Community Reinvestment Act to credit unions Merchant Category Codes H.R. 1181, Protecting Privacy in Purchases Act H.R.1602, Financial Privacy Act of 2025 Foreign Affiliate Sharing Pilot Program Extension Act Financial Innovation and Technology for the 21st Century Act H.R.1631, Safe Access to Cash Act of 2025 H.R.2885, Bank Loan Privacy Act H.R. 941, Small Lender Act Regulation II: Debit Card Interchange Fees and Routing Implementation of Dodd-Frank Act Section 1033: Final Rule on Personal Financial Data Rights Merger and Acquisition Policy Artificial Intelligence Risk Management, Regulation, and Innovation CDFI Certification & Funding Federal Reserve Discount Window and Emergency Lending Authority Tokenization of Assets Fraud Issues Peer-To-Peer Payment Fraud Financial Data Transparency Act Rulemaking FDIC Brokered Deposit Proposal H.R. 3633, the Digital Asset Market Clarity (CLARITY) Act of 2025 H.R.1900 - Bank Failure Prevention Act of 2025 H.R.3230 - Financial Institution Regulatory Tailoring Enhancement Act H.R.8287 - Stress Testing Accountability and Transparency Act H.R. 2835, the Small Bank Holding Company Relief Act H.R. 3709, the Advancing the Mentor-Protege Program for Small Financial Institutions Act H.R. 3716, the Systemic Risk Authority Transparency Act H.R. 940, the Fair Audits and Inspections for Regulators' (FAIR) Exams Act H.R. 3379, the Halting Uncertain Methods and Practices in Supervision (HUMPS) Act of 2025 H.R. 3380, the Taking Account of Institutions with Low Operation Risk (TAILOR) Act of 2025 S.2019 - Task Force for Recognizing and Averting Payments Scams (TRAPS) Act H.R. 3390, the Bringing the Discount Window into the 21st Century Act H.R. 4460, the Stop Agency Fiat Enforcement of Guidance (SAFE Guidance) Act H.R. 3446, the FDIC Board Accountability Act H.R. 4544, The American Access to Banking Act H.R. 4478, the Tailored Regulatory Updates for Supervisory Testing Act of 2025 (TRUST Act) H.R. 4437, the Supervisory Modifications for Appropriate Risk-Based Testing Act of 2025 (SMART Act) H.R. 5270, the Stress Testing Accountability and Transparency Act H.R. 5276, the Community Bank Leverage Improvement and Flexibility for Transparency (Community Bank LIFT) Act H.R. 5291, the Merchant Banking Modernization Act H.R. 5262, the Bank Competition Modernization Act Legislation to support Minority Depository Institutions H.R. 6553, the Tailoring and Indexing Enhanced Regulations (TIER) Act H.R. 6554, the Community Bank Representation Act H.R. 6536, Rural Depositories Revitalization Study Act H.R. 6551, the New Bank Application Numbers Knowledge Act (New BANK) Act H.R. 6546, Merger Process Review Act H.R. 6570, the Merger Agreement Approvals Clarity and Predictability Act H.R. 6544, The Regulatory Efficiency, Verification, Itemization, and Enhanced Workflow (REVIEW) Act H.R. 6550, the American Financial Institution Regulatory Sovereignty and Transparency (American FIRST) Act H.R. 6555, the Enhancing Bank Resolution Participation Act Ensuring Fair Access to Banking Act

H.R. 1 One Big Beautiful Bill Act authority and effectiveness of the Vice Chair for Supervision by inserting a bank-friendly Board member into the development of policy related to bank supervision and regulation HR 3682 Financial Stability Oversight Council Improvement Act HR 5262 Bank Competition Modernization Act HR 5270 Stress Testing Accountability and Transparency Act HR 5276 Community Bank LIFT Act HR 5291 Merchant Banking Modernization Act HR 5317 Community Bank Deposit Access Act private equity regulation private equity in health care Crypto Regulatory Legislation digital assets regulation Central Bank Digital Currency Digital assets regulation (stablecoins; banking standards for crypto) S. 1582 GENIUS Act (stablecoins) S. 710 Crypto ATM Fraud Prevention Act H. R. 1919 Anti-CBDC Surveillance State Act H.R. 3633, the CLARITY Act (crypto market regulation) Responsible Financial Innovation Act

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

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

H.R. 478 The Promoting New Bank Formation Act H.R. 940 The FAIR Exams Act H.R. 941 The Small LENDER Act H.R. 975 Credit Union Board Modernization Act H.R. 976 The 1071 Repeal to Protect Small Business Lending Act H.R. 1606 Making the CFPB Accountable to Small Businesses Act H.R. 1652 Rectifying UDAAP Act H.R. 1799 The Financial Reporting Threshold Modernization Act H.R. 1919 Anti-CBDC Surveillance State Act H.R. 1944 10 Percent Credit Card Interest Rate Cap Act H.R. 2808 The Homebuyers Privacy Protection Act H.R. 2392 Stablecoin Transparency and Accountability for a Better Ledger Economy Act of 2025 H.R. 2835 The Small Bank Holding Company Relief Act H.R. 2885 The Bank Loan Privacy Act H.R. 3234 Reciprocal Deposits H.R. 3380 TAILOR Act of 2025 H.R. 3390 Bringing the Discount Window into the 21st Century Act H.R. 3446 FDIC Board Accountability Act- Rep. Huizenga H.R. 3633 The CLARITY Act H.R. 3709 Advancing the Mentor-Protege Program for Small Financial Institutions Act H.R. 4437 SMART Act H.R. 4478 TRUST Act H.R. 5079 Widespread Information Management for the Welfare of Infrastructure and Government Act H.R. 5262 The Bank Competition Modernization Act H.R. 5276 The Community Bank LIFT Act H.R. 5263 The Bank Competition Modernization Act H.R. 5291 The Merchant Banking Modernization Act H.R. 5317 The Community Bank Deposit Access Act of 2025 H.R. 8071 Fair Exams Act S. 113 The Promoting New Bank Formation Act S. 394 Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 S. 427 The TAILOR Act S. 557 The 1071 Repeal to Protect Small Business Lending Act S. 1124 Anti-CBDC Surveillance State Act S. 1260 Rural Housing Service Reform Act of 2025 - SEC. 301. Native CDFI Relending Program S. 1467 Homebuyers Privacy Protection Act S. 1582 Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 S. 1880 CDFI Bond Guarantee Improvement Act S. 2296 National Defense Authorization Act S. 2352 The PROTECTED Act S. 2486 Protecting Access to Credit for Small Businesses Act S. 2663 Merchant Banking Modernization Act S. 2704 CDFI Fund Transparency Act S. 2999 Main Street Depositor Protection Act S.J. Res 18 CRA Resolution Disapproving of the CFPB Overdraft Rule Amendment 3640 to S. 2296 National Defense Authorization Act - CDFIs Amendment 3649 to the S. 2296 National Defense Authorization Act - Deposit Insurance Artificial Intelligence Bank Loan Privacy Act Central Bank Digital Currency CFPB 1033 Rule Community Bank Access to Capital Community Development Financial Institutions Certification Community Reinvestment Act Credit Card Competition Act/Credit Routing Credit Reporting Credit Union Acquisitions of Community Banks Credit Union Business Lending Powers Credit Union Field of Membership Rules Cybersecurity Information Sharing Act (CISA) Reauthorization Data Privacy De Novo Bank Formation Deposit Insurance Digital Assets Regulation EGRPRA Review Federal Reserve Master Accounts FHFA Capital Rules Flood Insurance Fraud and Scams Gramm-Leach-Bliley Act (GLBA) Industrial Loan Company Charter Policy Issues related to the Federal Home Loan Bank Act Minority Depository Institutions Mutual Bank Capital Certificates Regulatory Relief Responsible Financial Innovation Act Stablecoin Regulation

H.R. 478 The Promoting New Bank Formation Act H.R. 940 The FAIR Exams Act H.R. 941 The Small LENDER Act H.R. 975 Credit Union Board Modernization Act H.R. 976 The 1071 Repeal to Protect Small Business Lending Act H.R. 1606 Making the CFPB Accountable to Small Businesses Act H.R. 1652 Rectifying UDAAP Act H.R. 1799 The Financial Reporting Threshold Modernization Act H.R. 1919 Anti-CBDC Surveillance State Act H.R. 1944 10 Percent Credit Card Interest Rate Cap Act H.R. 2808 The Homebuyers Privacy Protection Act H.R. 2392 Stablecoin Transparency and Accountability for a Better Ledger Economy Act of 2025 H.R. 2835 The Small Bank Holding Company Relief Act H.R. 2885 The Bank Loan Privacy Act H.R. 3234 Reciprocal Deposits H.R. 3380 TAILOR Act of 2025 H.R. 3390 Bringing the Discount Window into the 21st Century Act H.R. 3446 FDIC Board Accountability Act- Rep. Huizenga H.R. 3633 The CLARITY Act H.R. 3709 Advancing the Mentor-Protege Program for Small Financial Institutions Act H.R. 4437 SMART Act H.R. 4478 TRUST Act H.R. 5079 Widespread Information Management for the Welfare of Infrastructure and Government Act H.R. 5262 The Bank Competition Modernization Act H.R. 5276 The Community Bank LIFT Act H.R. 5263 The Bank Competition Modernization Act H.R. 5291 The Merchant Banking Modernization Act H.R. 5317 The Community Bank Deposit Access Act of 2025 H.R. 8071 Fair Exams Act S. 113 The Promoting New Bank Formation Act S. 394 Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 S. 427 The TAILOR Act S. 557 The 1071 Repeal to Protect Small Business Lending Act S. 1124 Anti-CBDC Surveillance State Act S. 1260 Rural Housing Service Reform Act of 2025 - SEC. 301. Native CDFI Relending Program S. 1467 Homebuyers Privacy Protection Act S. 1582 Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 S. 1880 CDFI Bond Guarantee Improvement Act S. 2296 National Defense Authorization Act S. 2352 The PROTECTED Act S. 2486 Protecting Access to Credit for Small Businesses Act S. 2663 Merchant Banking Modernization Act S. 2704 CDFI Fund Transparency Act S. 2999 Main Street Depositor Protection Act S.J. Res 18 CRA Resolution Disapproving of the CFPB Overdraft Rule Amendment 3640 to S. 2296 National Defense Authorization Act - CDFIs Amendment 3649 to the S. 2296 National Defense Authorization Act - Deposit Insurance Artificial Intelligence Bank Loan Privacy Act Central Bank Digital Currency CFPB 1033 Rule Community Bank Access to Capital Community Development Financial Institutions Certification Community Reinvestment Act Credit Card Competition Act/Credit Routing Credit Reporting Credit Union Acquisitions of Community Banks Credit Union Business Lending Powers Credit Union Field of Membership Rules Cybersecurity Information Sharing Act (CISA) Reauthorization Data Privacy De Novo Bank Formation Deposit Insurance Digital Assets Regulation EGRPRA Review Federal Reserve Master Accounts FHFA Capital Rules Flood Insurance Fraud and Scams Gramm-Leach-Bliley Act (GLBA) Industrial Loan Company Charter Policy Issues related to the Federal Home Loan Bank Act Minority Depository Institutions Mutual Bank Capital Certificates Regulatory Relief Responsible Financial Innovation Act Stablecoin Regulation

CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Appropriate Regulation of Fintechs and Innovations in Financial Services The pace of innovation in financial services has been accelerating. Many of these new services are offered by financial technology companies - better known as fintechs. Financial innovation presents community banks with challenges and opportunities. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose unreasonable requirements on them, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Prescriptive and Intrusive FDIC Corporate Governance Guidelines In 2023, the FDIC proposed new corporate governance and risk management guidelines. Although the guidelines only apply to covered institutions with $10 billion or more in assets, these overly prescriptive guidelines apply the same set of standards to larger community banks as they do to the nations largest banks. These guidelines would make it even more difficult to attract new directors, particularly those in rural areas. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. De Novo Community Bank Formation, the Dual Banking System, and Charter Choice The chartering of many newly chartered (de novo) community banks is vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of continued banking industry consolidation. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, where chartering and supervision are divided between the federal government and the states, and where the federal government supervision and regulation is divided between the Federal Reserve, Office of Comptroller of the Currency, and the Federal Deposit Insurance Corporation. Community banks should be able to choose the banking charter and associated prudential regulator that best fits their unique needs and business model. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. Responsible Bank Merger Activity Some community banks have found it helpful to merge with other community banks to be able to spread the significant and escalating costs of regulatory compliance, cybersecurity, technology and innovation to remain highly competitive. Restrictive bank merger legislation or regulations should not apply to community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Insure) Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts Too-Big-To-Not-Insure The 2023 failures of Silicon Valley Bank and Signature Bank revealed that policymakers have created a new category of very large banks - Too-Big-To-Not-Insure (although they will fail) because the FDIC decided to insure 100% of the uninsured deposits of these two failed banks. There must be accountability by both the banks and the regulators for their respective failures. In the future, if systemically important financial institutions (SIFIs) cause losses to the DIF then SIFIs should be responsible for reimbursing the DIF for all the losses they created. Too-Big-To-Fail The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 4437 or the SMART Act and H.R. 4478 or the TRUST Act (All Sections) regarding extended and limited scope regulatory examinations (House) H.R. 3633 or the CLARITY Act (All Sections) and S. 394 or the GENIUS Act (All Sections) regarding stablecoins and ICBA/CBAI guiding principles (House, Senate) H.R. 3446 or the FDIC Board Accountability Act (All Sections) and H.R. 3390 or the Bringing the Discount into the 21st Century Act (All Sections) regarding the composition of the FDIC Board and modernizing the Feds Discount Window borrowings (House) H. R. 5276 or the LIFT Act or the Community Bank Capital Flexibility and Growth Act (All Sections) regarding the threshold for the CBLR. H.R. 2808 the Homebuyers Privacy Protection Act (All Sections) to protect the financial privacy of mortgage applicants by restricting the sale of trigger leads (House and Senate) Letters - Comment Letter to the OCC, Federal Reserve and the FDIC regarding Request for Information and Comment on Potential Actions to Address Payments Fraud [Check Fraud] - Docket ID OCC-2025-0009, RIN 3064-ZA49 and Docket No. OP-1866 (OCC, Federal Reserve and FDIC) ICBA State Association letter to the OCC, Federal Reserve and the FDIC regarding Request for Information and Comment on Potential Actions to Address Payments Fraud [Check Fraud] - Docket ID OCC-2025-0009, RIN 3064-ZA49 and Docket No. OP-1866 (OCC, Federal Reserve and FDIC) ICBA State Association letter to U.S. Department of the Treasury regarding the implementation of the ACRE Act of 2025 in the One Big Beautiful Bill Act (specifically Section 139L and 139L(c)(1)(A) and 139L(c)(2)) concerning secured by rural and agricultural real estate and refinancings (Treasury) Action Alerts - Action Alert - Urge the Banking Regulators to Address Check Fraud regarding the joint regulator Request for Information concerning payments fraud - Docket ID OCC-2025-0009, RIN 3064-ZA49 and Docket No. OP-1866 (OCC, Federal Reserve and FDIC) Miscellaneous - Pig Butchering Scams (Federal Reserve and OCC) Community Bank Conference in Washington, D.C. (Federal Reserve) Affordable Housing challenges (House) Check Fraud (House, Senate, OCC, Federal Reserve and FDIC) Capital One-Discover merger (House) Recent senior leadership appointments at the FDIC (FDIC)

CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Appropriate Regulation of Fintechs and Innovations in Financial Services The pace of innovation in financial services has been accelerating. Many of these new services are offered by financial technology companies - better known as fintechs. Financial innovation presents community banks with challenges and opportunities. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose unreasonable requirements on them, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Prescriptive and Intrusive FDIC Corporate Governance Guidelines In 2023, the FDIC proposed new corporate governance and risk management guidelines. Although the guidelines only apply to covered institutions with $10 billion or more in assets, these overly prescriptive guidelines apply the same set of standards to larger community banks as they do to the nations largest banks. These guidelines would make it even more difficult to attract new directors, particularly those in rural areas. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. De Novo Community Bank Formation, the Dual Banking System, and Charter Choice The chartering of many newly chartered (de novo) community banks is vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of continued banking industry consolidation. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, where chartering and supervision are divided between the federal government and the states, and where the federal government supervision and regulation is divided between the Federal Reserve, Office of Comptroller of the Currency, and the Federal Deposit Insurance Corporation. Community banks should be able to choose the banking charter and associated prudential regulator that best fits their unique needs and business model. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. Responsible Bank Merger Activity Some community banks have found it helpful to merge with other community banks to be able to spread the significant and escalating costs of regulatory compliance, cybersecurity, technology and innovation to remain highly competitive. Restrictive bank merger legislation or regulations should not apply to community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Insure) Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts Too-Big-To-Not-Insure The 2023 failures of Silicon Valley Bank and Signature Bank revealed that policymakers have created a new category of very large banks - Too-Big-To-Not-Insure (although they will fail) because the FDIC decided to insure 100% of the uninsured deposits of these two failed banks. There must be accountability by both the banks and the regulators for their respective failures. In the future, if systemically important financial institutions (SIFIs) cause losses to the DIF then SIFIs should be responsible for reimbursing the DIF for all the losses they created. Too-Big-To-Fail The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 4437 or the SMART Act and H.R. 4478 or the TRUST Act (All Sections) regarding extended and limited scope regulatory examinations (House) H.R. 3633 or the CLARITY Act (All Sections) and S. 394 or the GENIUS Act (All Sections) regarding stablecoins and ICBA/CBAI guiding principles (House, Senate) H.R. 3446 or the FDIC Board Accountability Act (All Sections) and H.R. 3390 or the Bringing the Discount into the 21st Century Act (All Sections) regarding the composition of the FDIC Board and modernizing the Feds Discount Window borrowings (House) H. R. 5276 or the LIFT Act or the Community Bank Capital Flexibility and Growth Act (All Sections) regarding the threshold for the CBLR. H.R. 2808 the Homebuyers Privacy Protection Act (All Sections) to protect the financial privacy of mortgage applicants by restricting the sale of trigger leads (House and Senate) Letters - Comment Letter to the OCC, Federal Reserve and the FDIC regarding Request for Information and Comment on Potential Actions to Address Payments Fraud [Check Fraud] - Docket ID OCC-2025-0009, RIN 3064-ZA49 and Docket No. OP-1866 (OCC, Federal Reserve and FDIC) ICBA State Association letter to the OCC, Federal Reserve and the FDIC regarding Request for Information and Comment on Potential Actions to Address Payments Fraud [Check Fraud] - Docket ID OCC-2025-0009, RIN 3064-ZA49 and Docket No. OP-1866 (OCC, Federal Reserve and FDIC) ICBA State Association letter to U.S. Department of the Treasury regarding the implementation of the ACRE Act of 2025 in the One Big Beautiful Bill Act (specifically Section 139L and 139L(c)(1)(A) and 139L(c)(2)) concerning secured by rural and agricultural real estate and refinancings (Treasury) Action Alerts - Action Alert - Urge the Banking Regulators to Address Check Fraud regarding the joint regulator Request for Information concerning payments fraud - Docket ID OCC-2025-0009, RIN 3064-ZA49 and Docket No. OP-1866 (OCC, Federal Reserve and FDIC) Miscellaneous - Pig Butchering Scams (Federal Reserve and OCC) Community Bank Conference in Washington, D.C. (Federal Reserve) Affordable Housing challenges (House) Check Fraud (House, Senate, OCC, Federal Reserve and FDIC) Capital One-Discover merger (House) Recent senior leadership appointments at the FDIC (FDIC)