Payday Lending Limitation Act of 2010

Monitored congressional action of the reauthorization of the EB-5 Regional Center Investment Pilot Program (S. 3245) and several other key immigration-related programs (the E-Verify Program, the Special Immigrant Nonminister Religious Worker Program, and the Conrad State 30 J-1 Visa Waiver Program).

Client expense: Not reported · Firm income: $10,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Monitored congressional action of the reauthorization of the EB-5 Regional Center Investment Pilot Program (S. 3245) and several other key immigration-related programs (the E-Verify Program, the Special Immigrant Nonminister Religious Worker Program, and the Conrad State 30 J-1 Visa Waiver Program).

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Lobbying issues were: CFPA (encouraging Congress to create an effective federal consumer-focused banking regulator); credit cards (encouraging Congress to speed up the implementation of the Federal Reserve's new regulations and to add additional consumer protections); overdraft loans (encouraging Congress to implement restrictions on abusive overdraft practices); payday loans (encouraging Congress to prohibit abusive products and practices); [continued on next page] [continued from previous page] mortgage lending (encouraging Congress to prohibit abusive products and practices); mortgage loan modifications (encouraging Congress to provide incentive for servicers to modify loans to prevent foreclosures) Specific legislation that was the subject of lobbying activity: S61: Helping Families Save their Homes in Bankruptcy Act of 2009 (to allow for judicial loan modification for primary residences through the bankruptcy code) S257: Consumer Credit Fairness Act (to require the bankruptcy court to disallow any claim arising from an abusive high cost consumer credit transaction) S500: Protecting Consumers from Unreasonable Credit Rates Act of 2009 (to create a federal 36% APR usury cap) S585: Taxpayer Abuse Prevention Act (to provide additional protections for recipients of the earned income tax credit) S786: Improving Access to Mainstream Financial Institutions Act of 2009 (to establishing alternative small-dollar lending program to payday loans) S2824: Amendment to Community Development Banking and Financial Institutions Act of 1994 (to establish a small dollar loan-loss guarantee fund that insures fair and affordable small dollar loans) S3217: Restoring American Financial Stability Act of 2010, and related amendments (to create a single agency to have strong rulewriting and enforcement authority in consumer financial transactions) S3245: The Payday Lending Limitation Act of 2010 (to limit abusive aspects of payday loans) S.AMDT.4311 to HR4213: Franken/Snowe Amendment (to create an Office of the Homeowner Advocate) HR200: Helping Families Save Their Homes in Bankruptcy Act of 2009 (to allow for judicial loan modifications for primary residences through the bankruptcy code) HR225: Emergency Homeownership and Equity Protection Act (to allow for judicial loan modification for primary residences through the bankruptcy code) HR1106: Helping Families Save their Homes Act of 2009 (to allow for judicial loan modification for primary residences through the bankruptcy code) HR1214: Payday Loan Reform Act of 2009 (to limit the most abusive aspects of payday loans) HR1456: Consumer Overdraft Protection Fair Practices Act (to create federal protections against abusive and unfair overdraft practices) HR1608: Protecting Consumers from Unreasonable Credit Rates Act of 2009 (to create a federal 36% APR usury cap) HR1637: Universal Default Prohibition Act of 2009 (to eliminate universal increases in interest rate on a credit card when cardholders default on accounts with other creditors) HR1782: Fairness for Homeowners Act of 2009 (to protect consumers against abusive, unfair, or deceptive practices in the mortgage marketplace) HR1846: Consumer Lending Education And Reform Act (opposed the mere disclosure of abusive terms in payday loans and favored substantive consumer protections) HR2309: Consumer Credit and Debt Protection Act (to grant the FTC expedited rule-making authority) HR2563: Payday Lending Reform Act of 2009 (opposed the mere disclosure of abusive terms in payday loans and favored substantive consumer protections) HR3904: Overdraft Protection Act of 2009 (to create federal protections against abusive and unfair overdraft practices) HR4173: The Wall Street Reform and Consumer Protection Act of 2009, and related amendments (to create a single agency to have strong rulewriting and enforcement authority in consumer financial transactions, and to protect consumers against abusive, unfair, or deceptive practices in the mortgage marketplace) HR4229: Borrowers' Right to Inspect Closing Documents Act of 2009 (to require more timely delivery of loan and closing documents to borrower) HR4300: Restoring America's Commitment to Consumers Act of 2009 (favoring a 36% inclusive interest rate cap) HR5689: Predatory Lending Sunset Act (to place a cap on the rate of interest allowed on small-dollar consumer loans) HR5942: FFSCC Act of 2010 (to protect existing state laws limiting abusive payday lending practices) House and Senate GSE Bills, not yet introduced (to ensure there is a secondary housing market to serve low- and moderate-income communities) Freedom of Mobility in Banking Act, not yet introduced (to facilitate consumers' ability to change banking accounts, including protection from unfair related fees) Executive branch agencies and issues: Dept. of Treasury -- Consumer Financial Protection Agency, HAMP, GSE reform, Bank On program Federal Trade Commission -- debt settlement, auto financing Banking agencies (Federal Reserve System, FDIC, OCC, OTS) -- testified at hearing on reforms to Community Reinvestment Act HUD -- GSE reform FDIC -- overdraft loans Federal Reserve -- overdraft loans, bank payday loans, mortgage rules, credit card rules, Dodd-Frank implementation NCUA -- overdraft loans and small dollar loans White House Office -- foreclosure prevention

Eliminate predatory lending; ensure equal access to financial services to all Americans. Eliminate disparities in credit reporting. Ease home mortgage foreclosure crisis. Eliminate pay day lending (concerns about H.R. 1214). Support capping all interest rates at 36% APR (support H.R. 1608 / S. 500). Support a foreclosure moratorium (H.R. 527 / S. 241). Oppose "vulture funds". Support debt relief for poor nations, a.k.a. the Jubilee Act. Reform the mortgage servicers industry so that more loans are modified and fewer homes are foreclosed upon. Try to ensure that homeowner facing foreclosure are not forgotten in the Wall Street bailout. Try to stop abusive credit card practices (support H.R. 627 / S. 414). Support H.R. 200 / H.R. 1106 / S. 61, which allows bankruptcy judges to require loan modifications on primary residence mortgages. Support reauthorization, modernization and expansion of the Community Reinvestment Act (CRA), support H.R. 1479. Support efforts to eliminate predatory loans; support 1728. Oppose payday loans; working to improve H.R. 1214. Support 36% interest rate cap; support H.R. 1608 / S. 500. Support legislation to toughen financial fraud investigations and sentences; support S. 386. Support legislation to make it easier for homeowners to modify their mortgages through federal programs; support S. 896. Support the creation of a Consumer Financial Protection Agency (CFPA) with strong civil rights mandates. Support financial literacy programs. Support an increase the demographic diversity of the financial services industry. Support H.R. 4173. Oppose exempting auto dealers from newly created CFPA. Oppose exempting college loans from CFPA. Oppose allowing CFPA, and all federal lending laws, to preempt stronger state laws. Support regulations to shut down yield spread premiums to mortgage brokers. Support financial counseling. oppose exempting Rent-to-Own operations from CFPA oversight. Support for the Benefit Card Fairness Act, H.R. 4552. Support creation of a strong CFPA, without exempting car dealers or student lenders, rent-to-own stores or payday lenders from its purview. Oppose federal preemption of state consumer financial protection laws. Ensure that rogue auto dealers are not exempted from the authority of the newly created Consumer Financial Protection Bureau, while at the same time ensuring that small, minority owned auto dealers who are fair to consumers are not run out of business. Support the creation of a strong, independent Consumer Financial Protection Bureau in H.R. 4173. Support S. 3245, the Payday Limitation Act of 2010. This legislation takes an aggressive approach to eliminating the worst of the payday debt trap problems. Support final passage of the conference report for H.R. 4173, the Restoring American Financial Stability Act. Support S. 3217, the Restoring American Financial Stability Act of 2010. Support H.R. 3149, the Equal Employment for All Act, which would outlaw the use of credit scores by potential employers when making hiring decisions. Support Creation of the Offices of Minority and Women Inclusion Under the Restoring American Financial Stability Act of 2010. Support FDIC guidence issued on limiting abusive overdract practices. Support Elizabeth Warren to be the first head of the Consumer Financial Protection Bureau. Support allowing consumers to close a bank account without incurring onerous fees. Support consumer-friendly, civil rights based changes to GSEs (Fannie Mae and Freddie Mac)

Eliminate predatory lending; ensure equal access to financial services to all Americans. Eliminate disparities in credit reporting. Ease home mortgage foreclosure crisis. Eliminate pay day lending (concerns about H.R. 1214). Support capping all interest rates at 36% APR (support H.R. 1608 / S. 500). Support a foreclosure moratorium (H.R. 527 / S. 241). Reform the mortgage servicers industry so that more loans are modified and fewer homes are foreclosed upon. Try to ensure that homeowners facing foreclosure are not forgotten in the Wall Street bailout. Try to stop abusive credit card practices (support H.R. 627 / S. 414). Support H.R. 200 / H.R. 1106 / S. 61, which allows bankruptcy judges to require loan modifications on primary residence mortgages. Oppose payday lending, working to help improve H.R. 1214. Support efforts to eliminate predatory lending. Support H.R. 1728. Support the establishment of a Consumer Financial Protection Agency (working to improve H.R. 3126). Support reauthorization, modernization and expansion of the Community Reinvestment Act (CRA), support H.R. 1479. Support 36% interest rate cap; support H.R. 1608 / S. 500. Work to eliminate the debt trap caused by payday lenders. Support financial literacy programs. Support H.R. 4173. Oppose exempting auto dealers from newly created CFPA. Oppose exempting college loans from CFPA. Oppose allowing CFPA, and all federal lending laws, to preempt stronger state laws. Support regulations to shut down yield spread premiums to mortgage brokers. Oppose the proposed Adverse Market Delivery Charge (AMDC) as well as the series of Loan Level Price Adjustments (LLPAs) under consideration by Fannie Mae and Freddie Mac. Ensure that rogue auto dealers are not exempted from the authority of the newly created Consumer Financial Protection Bureau, while at the same time ensuring that small, minority owned auto dealers who are fair to consumers are not run out of business. Support the creation of a strong, independent Consumer Financial Protection Bureau in H.R. 4173. Support S. 3245, the Payday Limitation Act of 2010. This legislation takes an aggressive approach to eliminating the worst of the payday debt trap problems. Support final passage of the conference report for H.R. 4173, the Restoring American financial Stability Act. Support S. 3217, the Restoring American Financial Stability Act of 2010. Support H.R. 3421, the The Medical Debt Relief Act of 2009. Support the creation of the Offices of Minority and Women Inclusion Under the Restoring American Financial Stability Act of 2010. Support a ban on the use of credit reports by potential employers. Support H.R. 3149. Support FDIC guidence issued on limiting abusive overdract practices. Support Elizabeth Warren to be the first head of the Consumer Financial Protection Bureau. Support allowing consumers to close a bank account without incurring onerous fees. Support pro-consumer changes to the GSEs (Fannie Mae and Freddie Mac). Support the President's veto of H. R. 3808, the Interstate Recognition of Notarizations Act of 2010 due to concerns that it would make it easier for large, interstate financial services companies to erroneously foreclose on homes.

H.R.4173, Dodd-Frank Wall Street Reform and Consumer Protection Act; H.R.2563, Payday Lending Reform Act of 2009; H.R.1214, Payday Loan Reform Act of 2009; S.3245, Payday Lending Limitation Act of 2010; Issues related to short term lending, amending the Truth in Lending Act and the Regulation Reform Act.

Client expense: Not reported · Firm income: $50,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R.4173, Dodd-Frank Wall Street Reform and Consumer Protection Act; H.R.2563, Payday Lending Reform Act of 2009; H.R.1214, Payday Loan Reform Act of 2009; S.3245, Payday Lending Limitation Act of 2010; Issues related to short term lending, amending the Truth in Lending Act and the Regulation Reform Act.

Client expense: Not reported · Firm income: $60,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R.4173, Dodd-Frank Wall Street Reform and Consumer Protection Act; S.3217, Restoring American Financial Stability Act of 2010; H.R.2563, Payday Lending Reform Act of 2009; H.R.1214, Payday Loan Reform Act of 2009; S.3245, Payday Lending Limitation Act of 2010; Issues related to short term lending, amending the Truth in Lending Act and the Regulation Reform Act.

Client expense: Not reported · Firm income: $60,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Lobbying issues were: CFPA (encouraging Congress to create an effective federal consumer-focused banking regulator); credit cards (encouraging Congress to speed up the implementation of the Federal Reserve's new regulations and to add additional consumer protections); overdraft loans (encouraging Congress to implement restrictions on abusive overdraft practices); payday loans (encouraging Congress to prohibit abusive products and practices); [continued on next page] [continued from previous page] mortgage lending (encouraging Congress to prohibit abusive products and practices); mortgage loan modifications (encouraging Congress to provide incentive for servicers to modify loans to prevent foreclosures) Specific legislation that was the subject of lobbying activity: S61: Helping Families Save their Homes in Bankruptcy Act of 2009 (to allow for judicial loan modification for primary residences through the bankruptcy code) S257: Consumer Credit Fairness Act (to require the bankruptcy court to disallow any claim arising from an abusive high cost consumer credit transaction) S500: Protecting Consumers from Unreasonable Credit Rates Act of 2009 (to create a federal 36% APR usury cap) S585: Taxpayer Abuse Prevention Act (to provide additional protections for recipients of the earned income tax credit) S786: Improving Access to Mainstream Financial Institutions Act of 2009 (to establishing alternative small-dollar lending program to payday loans) S2824: Amendment to Community Development Banking and Financial Institutions Act of 1994 (to establish a small dollar loan-loss guarantee fund that insures fair and affordable small dollar loans) S3217: Restoring American Financial Stability Act of 2010, and related amendments (to create a single agency to have strong rulewriting and enforcement authority in consumer financial transactions) S3245: The Payday Lending Limitation Act of 2010 (to limit abusive aspects of payday loans) S.AMDT.4311 to HR4213: Franken/Snowe Amendment (to create an Office of the Homeowner Advocate) HR200: Helping Families Save Their Homes in Bankruptcy Act of 2009 (to allow for judicial loan modifications for primary residences through the bankruptcy code) HR225: Emergency Homeownership and Equity Protection Act (to allow for judicial loan modification for primary residences through the bankruptcy code) HR1106: Helping Families Save their Homes Act of 2009 (to allow for judicial loan modification for primary residences through the bankruptcy code) HR1214: Payday Loan Reform Act of 2009 (to limit the most abusive aspects of payday loans) HR1456: Consumer Overdraft Protection Fair Practices Act (to create federal protections against abusive and unfair overdraft practices) HR1608: Protecting Consumers from Unreasonable Credit Rates Act of 2009 (to create a federal 36% APR usury cap) HR1637: Universal Default Prohibition Act of 2009 (to eliminate universal increases in interest rate on a credit card when cardholders default on accounts with other creditors) HR1782: Fairness for Homeowners Act of 2009 (to protect consumers against abusive, unfair, or deceptive practices in the mortgage marketplace) HR1846: Consumer Lending Education And Reform Act (opposed the mere disclosure of abusive terms in payday loans and favored substantive consumer protections) HR2309: Consumer Credit and Debt Protection Act (to grant the FTC expedited rule-making authority) HR2563: Payday Lending Reform Act of 2009 (opposed the mere disclosure of abusive terms in payday loans and favored substantive consumer protections) HR3904: Overdraft Protection Act of 2009 (to create federal protections against abusive and unfair overdraft practices) HR4173: The Wall Street Reform and Consumer Protection Act of 2009, and related amendments (to create a single agency to have strong rulewriting and enforcement authority in consumer financial transactions, and to protect consumers against abusive, unfair, or deceptive practices in the mortgage marketplace) HR4229: Borrowers' Right to Inspect Closing Documents Act of 2009 (to require more timely delivery of loan and closing documents to borrower) HR4300: Restoring America's Commitment to Consumers Act of 2009 (favoring a 36% inclusive interest rate cap) HR5689: Predatory Lending Sunset Act (to place a cap on the rate of interest allowed on small-dollar consumer loans) HR5942: FFSCC Act of 2010 (to protect existing state laws limiting abusive payday lending practices) House and Senate GSE Bills, not yet introduced (to ensure there is a secondary housing market to serve low- and moderate-income communities) Freedom of Mobility in Banking Act, not yet introduced (to facilitate consumers' ability to change banking accounts, including protection from unfair related fees) Executive branch agencies and issues: Dept. of Treasury -- Consumer Financial Protection Agency, HAMP, GSE reform, Bank On program Federal Trade Commission -- debt settlement, auto financing Banking agencies (Federal Reserve System, FDIC, OCC, OTS) -- testified at hearing on reforms to Community Reinvestment Act HUD -- GSE reform FDIC -- overdraft loans

See addendum. Payday lending provisions in the following legislation: HR 4173, Dodd-Frank Wall Street Reform and Consumer Protection Act (Rep. Speier) HR 1600, Protecting Consumers from Unreasonable Credit Rates Act of 2009 (Usury rate cap) (Rep. Hinchey) HR 1640, Interest Rate Reduction Act (Sen. Durbin) S 500, Protecting Consumers from Unreasonable Credit Rates Act of 2009 (Sen. Sanders) S 582, Interest Rate Reduction Act (Sen. Hagan) S 3245, Lending Limitation Act of 2010 (Rep. Gutierrez) HR 1214, Payday Loan Reform Act of 2009 (Rep. Baca) HR 1846, C.L.E.A.R. Act (Rep. Shuler) HR 2563, Payday Lending Reform Act of 2009

Client expense: Not reported · Firm income: $240,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Eliminate predatory lending; ensure equal access to financial services to all Americans. Eliminate disparities in credit reporting. Ease home mortgage foreclosure crisis. Eliminate pay day lending (concerns about H.R. 1214). Support capping all interest rates at 36% APR (support H.R. 1608 / S. 500). Support a foreclosure moratorium (H.R. 527 / S. 241). Oppose "vulture funds". Support debt relief for poor nations, a.k.a. the Jubilee Act. Reform the mortgage servicers industry so that more loans are modified and fewer homes are foreclosed upon. Try to ensure that homeowner facing foreclosure are not forgotten in the Wall Street bailout. Try to stop abusive credit card practices (support H.R. 627 / S. 414). Support H.R. 200 / H.R. 1106 / S. 61, which allows bankruptcy judges to require loan modifications on primary residence mortgages. Support reauthorization, modernization and expansion of the Community Reinvestment Act (CRA), support H.R. 1479. Support efforts to eliminate predatory loans; support 1728. Oppose payday loans; working to improve H.R. 1214. Support 36% interest rate cap; support H.R. 1608 / S. 500. Support legislation to toughen financial fraud investigations and sentences; support S. 386. Support legislation to make it easier for homeowners to modify their mortgages through federal programs; support S. 896. Support the creation of a Consumer Financial Protection Agency (CFPA) with strong civil rights mandates. Support financial literacy programs. Support an increase the demographic diversity of the financial services industry. Support H.R. 4173. Oppose exempting auto dealers from newly created CFPA. Oppose exempting college loans from CFPA. Oppose allowing CFPA, and all federal lending laws, to preempt stronger state laws. Support regulations to shut down yield spread premiums to mortgage brokers. Support financial counseling. oppose exempting Rent-to-Own operations from CFPA oversight. Support for the Benefit Card Fairness Act, H.R. 4552. Support creation of a strong CFPA, without exempting car dealers or student lenders, rent-to-own stores or payday lenders from its purview. Oppose federal preemption of state consumer financial protection laws. Ensure that rogue auto dealers are not exempted from the authority of the newly created Consumer Financial Protection Bureau, while at the same time ensuring that small, minority owned auto dealers who are fair to consumers are not run out of business. Support the creation of a strong, independent Consumer Financial Protection Bureau in H.R. 4173. Support S. 3245, the Payday Limitation Act of 2010. This legislation takes an aggressive approach to eliminating the worst of the payday debt trap problems. Support final passage of the conference report for H.R. 4173, the Restoring American Financial Stability Act. Support S. 3217, the Restoring American Financial Stability Act of 2010. Support H.R. 3149, the Equal Employment for All Act, which would outlaw the use of credit scores by potential employers when making hiring decisions. Support Creation of the Offices of Minority and Women Inclusion Under the Restoring American Financial Stability Act of 2010. Support FDIC guidence issued on limiting abusive overdract practices. Support Elizabeth Warren to be the first head of the Consumer Financial Protection Bureau. Support allowing consumers to close a bank account without incurring onerous fees.

Eliminate predatory lending; ensure equal access to financial services to all Americans. Eliminate disparities in credit reporting. Ease home mortgage foreclosure crisis. Eliminate pay day lending (concerns about H.R. 1214). Support capping all interest rates at 36% APR (support H.R. 1608 / S. 500). Support a foreclosure moratorium (H.R. 527 / S. 241). Reform the mortgage servicers industry so that more loans are modified and fewer homes are foreclosed upon. Try to ensure that homeowners facing foreclosure are not forgotten in the Wall Street bailout. Try to stop abusive credit card practices (support H.R. 627 / S. 414). Support H.R. 200 / H.R. 1106 / S. 61, which allows bankruptcy judges to require loan modifications on primary residence mortgages. Oppose payday lending, working to help improve H.R. 1214. Support efforts to eliminate predatory lending. Support H.R. 1728. Support the establishment of a Consumer Financial Protection Agency (working to improve H.R. 3126). Support reauthorization, modernization and expansion of the Community Reinvestment Act (CRA), support H.R. 1479. Support 36% interest rate cap; support H.R. 1608 / S. 500. Work to eliminate the debt trap caused by payday lenders. Support financial literacy programs. Support H.R. 4173. Oppose exempting auto dealers from newly created CFPA. Oppose exempting college loans from CFPA. Oppose allowing CFPA, and all federal lending laws, to preempt stronger state laws. Support regulations to shut down yield spread premiums to mortgage brokers. Oppose the proposed Adverse Market Delivery Charge (AMDC) as well as the series of Loan Level Price Adjustments (LLPAs) under consideration by Fannie Mae and Freddie Mac. Ensure that rogue auto dealers are not exempted from the authority of the newly created Consumer Financial Protection Bureau, while at the same time ensuring that small, minority owned auto dealers who are fair to consumers are not run out of business. Support the creation of a strong, independent Consumer Financial Protection Bureau in H.R. 4173. Support S. 3245, the Payday Limitation Act of 2010. This legislation takes an aggressive approach to eliminating the worst of the payday debt trap problems. Support final passage of the conference report for H.R. 4173, the Restoring American financial Stability Act. Support S. 3217, the Restoring American Financial Stability Act of 2010. Support H.R. 3421, the The Medical Debt Relief Act of 2009. Support the creation of the Offices of Minority and Women Inclusion Under the Restoring American Financial Stability Act of 2010. Support a ban on the use of credit reports by potential employers. Support H.R. 3149. Support FDIC guidence issued on limiting abusive overdract practices. Support Elizabeth Warren to be the first head of the Consumer Financial Protection Bureau. Support allowing consumers to close a bank account without incurring onerous fees.

H.R.4173, Dodd-Frank Wall Street Reform and Consumer Protection Act; H.R.2563, Payday Lending Reform Act of 2009; H.R.1214, Payday Loan Reform Act of 2009; S.3245, Payday Lending Limitation Act of 2010; Issues related to short term lending, amending the Truth in Lending Act and the Regulation Reform Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

See addendum. Wall Street Reform Bill legislation: Speed bump amendment- requiring the new Bureau of Consumer Financial Protection (Bureau) when considering regulations to slow down and consider the impact on credit to small businesses and alternatives that might minimize any increase in such costs Sec 1021: provisions have wording indicating that the Bureaus purposes and objectives include implementing the federal law so as to ensure competitive markets for consumer financial products and consistent enforcement of the law to promote fair competition Title 12: small dollar loan vs. payday loans language in bill. Definition of payday Sec 1031: defining unfair, deceptive or abusive practices Arbitration provisions BCFP: rulemaking authority Hagan SA 3744 payday loans Whitehouse S.AMDT.3746 To restore to the States the right to protect consumers from usurious lenders. Slaughter/Tierney HR 4300 Restoring America's Commitment to Consumers Act of 2009. Usury rate cap Speier HR 1600 Protecting Consumers from Unreasonable Credit Rates Act of 2009. Usury rate cap Hinchey HR 1640 Interest Rate Reduction Act Durbin S.500 Protecting Consumers from Unreasonable Credit Rates Act of 2009 Sanders S.582 Interest Rate Reduction Act Hagan S.3245 Lending Limitation Act of 2010 Gutierrez HR 1214 Payday Loan Reform Act of 2009 Baca HR 1846 C.L.E.A.R. Act Shuler HR 2563 Payday Lending Reform Act of 2009

Client expense: Not reported · Firm income: $240,000

Lobbying issues were: CFPA (encouraging Congress to create an effective federal consumer-focused banking regulator); credit cards (encouraging Congress to speed up the implementation of the Federal Reserve's new regulations and to add additional consumer protections); overdraft loans (encouraging Congress to implement restrictions on abusive overdraft practices); payday loans (encouraging Congress to pass a 36% rate cap on consumer loans); [continued on next page] [continued from previous page] mortgage lending (encouraging Congress to prohibit abusive products and practices); mortgage loan modifications (encouraging Congress to provide incentives for servicers to modify loans to prevent foreclosures) Specific legislation that was subject of lobbying activity: S61: Helping Families Save their Homes in Bankruptcy Act of 2009 (to allow for judicial loan modification for primary residences through the bankruptcy code) S257: Consumer Credit Fairness Act (to require the bankruptcy court to disallow any claim arising from an abusive high cost consumer credit transaction) S500: Protecting Consumers from Unreasonable Credit Rates Act of 2009 (to create a federal 36% APR usury cap) S585: Taxpayer Abuse Prevention Act (to provide additional protections for recipients of the earned income tax credit) S1799: FAIR Overdraft Coverage Act of 2009 (to create federal protections against abusive and unfair overdraft practices) S2824: Amendment to Community Development Banking and Financial Institutions Act of 1994 to establish a small dollar loan-loss guarantee fund, and for other purposes (to establish a small dollar loan-loss guarantee fund that insures fair and affordable small dollar loans) S3217: Restoring American Financial Stability Act of 2010, and related amendments (to create a single agency to have strong rulewriting and enforcement authority in consumer financial transactions) S3245: The Payday Loan Limitation Act (to place a cap on the rate of interest allowed on payday loans) HR200: Helping Families Save Their Homes in Bankruptcy Act of 2009 (to allow for judicial loan modification for primary residences through the bankruptcy code) HR225: Emergency Homeownership and Equity Protection Act (to allow for judicial loan modification for primary residences through the bankruptcy code) HR1106: Helping Families Save their Homes Act of 2009 (to allow for judicial loan modification for primary residences through the bankruptcy code) HR1214: Payday Loan Reform Act of 2009 (to limit the most abusive aspects of payday loans) HR1456: Consumer Overdraft Protection Fair Practices Act (to create federal protections against abusive and unfair overdraft practices) HR1608: Protecting Consumers from Unreasonable Credit Rates Act of 2009 (to create a federal 36% APR usury cap) HR1637: Universal Default Prohibition Act of 2009 (to eliminate universal increases in interest rate on a credit card when cardholders default on accounts with other creditors) HR1728: Mortgage Reform and Anti-Predatory Lending Act (to protect consumers against abusive, unfair, or deceptive practices in the mortgage marketplace) HR1782: Fairness for Homeowners Act of 2009 (to protect consumers against abusive, unfair, or deceptive practices in the mortgage marketplace) HR1846: Consumer Lending Education And Reform Act (opposed the mere disclosure of abusive terms in payday loans and favored substantive consumer protections) HR2309: Consumer Credit and Debt Protection Act (to grant the FTC expedited rule-making authority) HR2563: Payday Lending Reform Act of 2009 (opposed the mere disclosure of abusive terms in payday loans and favored substantive consumer protections) HR3126: Consumer Financial Protection Agency Act of 2009 (to create a single agency to have strong rulewriting and enforcement authority in consumer financial transactions) HR3639: Expedited CARD Reform for Consumers Act of 2009 (to move up the effective date of the Credit CARD Act to December 1, 2009) HR3904: Overdraft Protection Act of 2009 (to create federal protections against abusive and unfair overdraft practices) HR4173: The Wall Street Reform and Consumer Protection Act of 2009, and related amendments (to create a single agency to have strong rulewriting and enforcement authority in consumer financial transactions) HR4229: Borrowers' Right to Inspect Closing Documents Act of 2009 (to require more timely delivery of loan and closing documents to borrower) HR5689: Predatory Lending Sunset Act (to place a cap on the rate of interest allowed on small-dollar consumer loans) Senate regulatory reform draft bill (not yet introduced) (to create a single agency to have strong rulewriting and enforcement authority in consumer financial transactions) Senate payday alternatives amendment (not yet introduced) (to create an alterative for abusive small-dollar loans) Senate FDIC payday standard (not yet introduced) (to create consumer protections for payday loan borrowers) Executive branch agencies and issues: Federal Reserve - Truth In Lending rescission rules Dept. of Treasury - Consumer Financial Protection Agency, HAMP Federal Trade Commission - debt settlement

Eliminate predatory lending; ensure equal access to financial services to all Americans. Eliminate disparities in credit reporting. Ease home mortgage foreclosure crisis. Eliminate pay day lending (concerns about H.R. 1214). Support capping all interest rates at 36% APR (support H.R. 1608 / S. 500). Support a foreclosure moratorium (H.R. 527 / S. 241). Reform the mortgage servicers industry so that more loans are modified and fewer homes are foreclosed upon. Try to ensure that homeowners facing foreclosure are not forgotten in the Wall Street bailout. Try to stop abusive credit card practices (support H.R. 627 / S. 414). Support H.R. 200 / H.R. 1106 / S. 61, which allows bankruptcy judges to require loan modifications on primary residence mortgages. Oppose payday lending, working to help improve H.R. 1214. Support efforts to eliminate predatory lending. Support H.R. 1728. Support the establishment of a Consumer Financial Protection Agency (working to improve H.R. 3126). Support reauthorization, modernization and expansion of the Community Reinvestment Act (CRA), support H.R. 1479. Support 36% interest rate cap; support H.R. 1608 / S. 500. Work to eliminate the debt trap caused by payday lenders. Support financial literacy programs. Support H.R. 4173. Oppose exempting auto dealers from newly created CFPA. Oppose exempting college loans from CFPA. Oppose allowing CFPA, and all federal lending laws, to preempt stronger state laws. Support regulations to shut down yield spread premiums to mortgage brokers. Oppose the proposed Adverse Market Delivery Charge (AMDC) as well as the series of Loan Level Price Adjustments (LLPAs) under consideration by Fannie Mae and Freddie Mac. Ensure that rogue auto dealers are not exempted from the authority of the newly created Consumer Financial Protection Bureau, while at the same time ensuring that small, minority owned auto dealers who are fair to consumers are not run out of business. Support the creation of a strong, independent Consumer Financial Protection Bureau in H.R. 4173. Support S. 3245, the Payday Limitation Act of 2010. This legislation takes an aggressive approach to eliminating the worst of the payday debt trap problems. Support final passage of the conference report for H.R. 4173, the Restoring American financial Stability Act. Support S. 3217, the Restoring American Financial Stability Act of 2010. Support H.R. 3421, the The Medical Debt Relief Act of 2009. Support the creation of the Offices of Minority and Women Inclusion Under the Restoring American Financial Stability Act of 2010

Eliminate predatory lending; ensure equal access to financial services to all Americans. Eliminate disparities in credit reporting. Ease home mortgage foreclosure crisis. Eliminate pay day lending (concerns about H.R. 1214). Support capping all interest rates at 36% APR (support H.R. 1608 / S. 500). Support a foreclosure moratorium (H.R. 527 / S. 241). Oppose "vulture funds". Support debt relief for poor nations, a.k.a. the Jubilee Act. Reform the mortgage servicers industry so that more loans are modified and fewer homes are foreclosed upon. Try to ensure that homeowner facing foreclosure are not forgotten in the Wall Street bailout. Try to stop abusive credit card practices (support H.R. 627 / S. 414). Support H.R. 200 / H.R. 1106 / S. 61, which allows bankruptcy judges to require loan modifications on primary residence mortgages. Support reauthorization, modernization and expansion of the Community Reinvestment Act (CRA), support H.R. 1479. Support efforts to eliminate predatory loans; support 1728. Oppose payday loans; working to improve H.R. 1214. Support 36% interest rate cap; support H.R. 1608 / S. 500. Support legislation to toughen financial fraud investigations and sentences; support S. 386. Support legislation to make it easier for homeowners to modify their mortgages through federal programs; support S. 896. Support the creation of a Consumer Financial Protection Agency (CFPA) with strong civil rights mandates. Support financial literacy programs. Support an increase the demographic diversity of the financial services industry. Support H.R. 4173. Oppose exempting auto dealers from newly created CFPA. Oppose exempting college loans from CFPA. Oppose allowing CFPA, and all federal lending laws, to preempt stronger state laws. Support regulations to shut down yield spread premiums to mortgage brokers. Support financial counseling. oppose exempting Rent-to-Own operations from CFPA oversight. Support for the Benefit Card Fairness Act, H.R. 4552. Support creation of a strong CFPA, without exempting car dealers or student lenders, rent-to-own stores or payday lenders from its purview. Oppose federal preemption of state consumer financial protection laws. Ensure that rogue auto dealers are not exempted from the authority of the newly created Consumer Financial Protection Bureau, while at the same time ensuring that small, minority owned auto dealers who are fair to consumers are not run out of business. Support the creation of a strong, independent Consumer Financial Protection Bureau in H.R. 4173. Support S. 3245, the Payday Limitation Act of 2010. This legislation takes an aggressive approach to eliminating the worst of the payday debt trap problems. Support final passage of the conference report for H.R. 4173, the Restoring American Financial Stability Act. Support S. 3217, the Restoring American Financial Stability Act of 2010. Support H.R. 3149, the Equal Employment for All Act, which would outlaw the use of credit scores by potential employers when making hiring decisions. Support Creation of the Offices of Minority and Women Inclusion Under the Restoring American Financial Stability Act of 2010.

H.R.4173, Dodd-Frank Wall Street Reform and Consumer Protection Act; S.3217, Restoring American Financial Stability Act of 2010; H.R.2563, Payday Lending Reform Act of 2009; H.R.1214, Payday Loan Reform Act of 2009; S.3245, Payday Lending Limitation Act of 2010; Issues related to short term lending, amending the Truth in Lending Act and the Regulation Reform Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE