Growing Deposit Insurance for the Future Act

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

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. 2152 The AI PLAN Act H.R. 2978 The GUARD 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. 4544 The American Access to Banking Act H.R. 4551 The Employee Paycheck and Small Business Protection Act H.R. 5276 The Community Bank LIFT Act H.R. 5291 The Merchant Banking Modernization Act H.R. 5317 The Community Bank Deposit Access Act of 2025 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. 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 H.R. 8278 The Fostering the Use of Technology to Uphold Regulatory Effectiveness in Supervision Act H.R. 8671 The Bank Fraud Technology Advancement Act H.R. 9331 the Strengthening Transaction Oversight and Preventing (STOP) Payments Fraud 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. 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 4182 The FARM Act Housing Expansion Artificial Intelligence CFPB 1033 Rule Community Bank Access to Capital Credit Card Competition Act Credit Union Acquisitions of Community Banks Credit Union Field of Membership Rules Critical Infrastructure Protection Cybersecurity Data Privacy De Novo Bank Formation Deposit Insurance Digital Assets Regulation EGRPRA Review Executive Order 14406: Restoring Integrity to Americas Financial System Executive Order 14409: Promoting Advanced Artificial Intelligence Innovation and Security Form 990 Initiative Fraud and Scams National Trust Bank Charter Rules and Applications Regulatory Relief Stablecoin Regulation Support for Kevin Warsh for Federal Reserve Board Chairman The Growing Deposit Insurance for the Future Act

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

Government targets: Consumer Financial Protection Bureau (CFPB), Executive Office of the President (EOP), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of, White House Office

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

Client expense: $890,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Executive Office of the President (EOP), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of, White House Office