Too Big to Fail, Too Big to Exist Act

Financial Regulatory Reform and Modernization - The Forum supports policies that ensure the saftey and soundness of financial institutions, promotes financial system stability, and protect the varied interests of depositors, consumers, and investorsThe "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. The Forum is also of the view that any cost of funding advantage enjoyed by large diversified banking companies is not associated with an expectation on the part of market participants regarding future bailouts, but rather is due to the market-recognized benefits of institutional size, diversification of activities and income streams, and the stability and predictability of large institution earnings.Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly to economic growth and job creation here at home. The Forum believes that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis. Liquidity Coverage Ratio -- Consistent with its promotion of policies that promote infrastructure investment and economic growth, the Forum is concerned that the current liquidity coverage ratio (LCR) that has been jointly proposed by the OCC, Federal Reserve and the FDIC, will increase costs and decrease liquidity for municipal bond issuers, driving up the cost of needed investments in public schools, roads, and other critical infrastructure. The Forum is supportive of H.R. 5461: to clarify the application of certain leverage and risk-based requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act, to improve upon the definitions provided for points and fees in connection with a mortgage transaction, and for other purposes. H.R. 5461 includes important technical corrections to the Dodd-Frank Act that will strengthen the Act and provide critical clarifications to better oversee our financial system while allowing for economic growth. The Forum remains neutral but is following the progress of H.R. 5421: The Financial Institution Bankruptcy Act of 2014.

Client expense: $375,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Justice, Dept of (DOJ), Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

H.R.1450 Too-Big-to-Fail, Too-Big-to-Exist Act; H.R. 1553 to improve the examination of depository institutions; S 685 Too-Big-to-Exist Act; S 727 A bill to improve the examination of depository institutions; S 731 and S 737 Basel III Study Bills; H.R. 508 Terrorism Risk Insurance Act of 202 Re-authorization Act of 2013; H.R. 613 Systemic Risk Mitigation Act; H.R. 677 Inter-affiliate Swap Clarification Act; H.R. 688 Credit Union Small Business Jobs Creation Act; H.R. 749 Eliminate Privacy Notice Confusion Act; H.R.992 Swaps Regulatory Improvement Act; H.R. 1221 Basel II Capital Impact Study Act; H.R. 1256 Swap Jurisdiction Certainty Act; S 100 Terminating the Expansion of Too-Big-to-Fail Act of 2013; S. 205 Responsible Consumer Financial Protection Regulations Act of 2013; S. 474 Swaps Regulatory Improvement Act; S 635 Privacy Notice Modernization Act of 2013; S. 798-TBTF Act; H.R. 450 Bureau of Consumer Financial Protection Accountability Act; S. 1217 Housing Finance Reform and Taxpayer Protection Act of 2013; H.R. 2410 Agriculture Rural Development, Food and Drug Administration and Related Agencies Appropriations Act, 2014; H.R. 3211, the "Mortgage Choice Act of 2013"; H.R. 3036, "To Amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to specify when bank holding companies may be subject to certain enhanced supervision and for other purposes"; Homeowner Flood Insurance Affordability Act of 2014; H.R. 4060 Systemic Risk Designation Improvement Act of 2014; TRIA Re-authorized Bills, H.R. 4871 and S. 2244; "Export-Import Bank Re-authorization"; H.R. 2673, the Portfolio Lending and Mortgage Access Act; H.R. 5016, Financial Services and General Government Appropriations Act of 2015.

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

Issues related to credit and debit cards, private student lending, bank regulation, consumer lending and consumer financial protection, amendments to FDI Act and GSE legislation, including HR4060, S113, S160, S451, S673, S685, S727, S798, S1018, S1048, S1159, S1217, S1241, S2224, S2200

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 1450 Too-Big-to-Fail, Too-Big-to-Exist Act; H.R. 1553 to improve the examination of depository instituions; S 685 Too-Big-to-Fail, Too-Big-to-Exist Act; S 727 A bill to improve the examination of depository institutions; S 731 and S 737 Basel III Study Bills; H.R. 508 Terrorism Risk Insurance Act of 2002 Reauthorization Act of 2013; H.R. 613 Systemic Risk Mitigation Act; H.R. 677 Interaffiliate Swap Clarification Act; H.R. 688 Credit Union Small Business Jobs Creation Act; H.R. 749 Eliminate Privacy Notice Confusion Act; H.R. 992 Swaps Regulatory Improvement Act; H.R. 1221 Basell II Capital Impact Study Act; H.R. 1256 Swap Jurisdiction Certainty Act; S 100 Terminating the Expansion of Too-Big-to-Fail Act of 2013; S. 205 Responsible Consumer Financial Protection Regulations act of 2013; S. 474 Swaps Regulatory Improvement Act; S. 635 Privacy Notice Modernization Act of 2013; S. 798-TBTF Act; H.R. 450 Bureau of Consumer Financial Protection Accountability Act; S. 1217-Housing Finance Reform and Taxpayer Protection Act of 2013; H.R. 2410-Agriculture Rural Development, Food and Drug Administration and Related Agencies Appropriations Act, 2014; H.R. 3211, the "Mortgage Choice Act of 2013"; H.R. 3036. "To amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to specify when bank holding companies may be subject to certain enchanced supervision and for other purposes"; Homeowner Flood Insurance Affordabililty Act of 2014; Systemic Risk Designation Improvement Act of 2014; TRIA Re-authorization Bills, H.R. 4871 and S. 2244; "Export-Import Bank Re-authorization"; H.R. 2673, the Portfolio Lending and Mortgage Access Act; H.R. 5016, Financial Services and General Government Appropriations Act of 2015.

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

S. 25; Stop Unfair Giveaways and Restrictions Act of 2011; entire bill. S. 685; Free Sugar Act of 2013; entire bill. H.R. 1385; Free Market Sugar Act; entire bill. H.R. 1739; entire bill. S. 954; Agriculture Reform, Foods and Jobs Act of 2013; entire bill. H.R. 1714; Dairy Freedom Act; entire bill. Draft Biodiesel Credit Legislation.

Client expense: $360,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to credit and debit cards, private student lending, bank regulation, consumer lending and consumer financial protection, amendments to FDI Act and GSE legislation, including HR4060, S113, S160, S451, S673, S685, S727, S798, S1018, S1048, S1159, S1217, S1241, S2224, S2200

Client expense: $530,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Financial Regulatory Reform and Modernization - The Forum supports reform and modernization of the financial regulatory system to ensure the safety and soundness of financial institutions, promote financial systemic stability, and protect the varied interests of depositors, consumers, and investors.The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. The Forum is also of the view that any cost of funding advantage enjoyed by large diversified banking companies is not associated with an expectation on the part of market participants regarding future bailouts, but rather is due to the market-recognized benefits of institutional size, diversification of activities and income streams, and the stability and predictability of large institution earnings.Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly to economic growth and job creation here at home. The Forum believes that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis. Liquidity Coverage Ratio -- Consistent with its promotion of policies that promote infrastructure investment and economic growth, the Forum is concerned that the current liquidity coverage ratio (LCR) that has been jointly proposed by the OCC, FED and the FDIC, will increase costs and decrease liquidity for municipal bond issuers, driving up the cost of needed investments in public schools, roads, and other critical infrastructure. Complementary Activities, Merchant Banking Activities, and Other Activities of Financial Holding Companies Related to Physical Commodities, Docket No. R-1479; RIN 7100 AE-10 - The Forum believes that allowing financial holding companies to continue to conduct physical commodities activities, all while applying the right safeguards, is an important aspect of ensuring the global competitiveness and openness of our American markets.

Issues related to credit and debit cards, private student lending, bank regulation, consumer lending and consumer financial protection, amendments to FDI Act and GSE legislation, including S113, S160, S451, S673, S685, S727, S798, S1018, S1048, S1159, S1217 and S1241

Client expense: $850,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 25; Stop Unfair Giveaways and Restrictions Act of 2011; entire bill. S. 685; Free Sugar Act of 2013; entire bill. H.R. 1385; Free Market Sugar Act; entire bill. H.R. 1739; Free Sugar Act of 2013; entire bill. S. 954; Agriculture Reform, Food and Jobs Act of 2013; entire bill. H.R. 1741; Dairy Freedom Act; entire bill. Draft Biodiesel Tax Credit legislation.

Client expense: $320,000 · Firm income: Not reported

Government targets: Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, SENATE

Financial Regulatory Reform and Modernization - The Forum supports reform and modernization of the financial regulatory system to ensure the safety and soundness of financial institutions, promote financial systemic stability, and protect the varied interests of depositors, consumers, and investors.The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly to economic growth and job creation here at home.The Forum believes that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis. Liquidity Coverage Ratio -- Consistent with its promotion of policies that promote infrastructure investment and economic growth, the Forum is concerned that the current liquidity coverage ratio (LCR) that has been jointly proposed by the OCC, FED and the FDIC, will increase costs and decrease liquidity for municipal bond issuers, driving up the cost of needed investments in public schools, roads, and other critical infrastructure.

H.R. 1450 Too-Big-to-Fail, Too-Big-to-Exist Act; H.R. 1553 to improve the examiniation of depository institutions; S 685 Too-Big-to Fail, Too-Big-to-Exist Act; S 727 A bill to improve the examination of depository institutions; S 731 and S 737-Basel III Study Bills; H.R.508 Terrorism Risk Insurance Act of 2002 Reauthorization Act of 2013; H.R. 613 Systemic Risk Mitigation Act; H.R. 677 Interaffiliate Swap Clarification Act; H.R. 688 Credit Union Small Business Jobs Creation Act; H.R. 749 Eliminate Privacy Notice Confusion Act; H.R. 992 Swaps Regulatory improvement Act; H.R. 1221 Basel II Capital Impact Study Act; H.R. 1256 Swap Jurisdiction Certainty Act; S 100 Terminating the Expansion of Too-Big-to Fail Act of 2013; S. 205 Responsible Consumer Financial Protection Regulations Act of 2013; S. 474 Swaps Regulatory Improvement Act; S. 635 Privacy Notice Modernization Act of 2013; S. 798-TBTF Act; H.R. 450-Bureau of Consumer Financial Protection Accountability Act; S. 1217-Housing Finance Reform and Taxpayer Protection Act of 2013; H.R. 2410-Agriculture, Rural Development, Food and Drug Administration and Related Agencies Appropriations Act, 2014; H.R. 3211, the "Mortgage Choice Act of 2013:' H.R. 3036, "To amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to specify when bank holding companies may be subject to certain enhanced supervision, and for other purposes"; Homeowner Flood Insurance Affordability Act of 2014; Systemic Risk Designation Improvement Act of 2014.

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

S. 25; Stop Unfair Giveaways and Restrictions Act of 2011; entire bill. S. 685; Free Sugar Act of 2013; entire bill. H.R. 1385; Free Market Sugar Act; entire bill. H.R. 1739; Free Sugar Act of 2013; entire bill.S. 954; Agriculture Reform, Food and Jobs Act of 2013; entire bill. H.R. 1741; Dairy Freedom Act; entire bill. Draft Biodiesel Tax Credit legislation.

Client expense: $270,000 · Firm income: Not reported

Government targets: Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, SENATE, U.S. Trade Representative (USTR)

Financial Regulatory Reform and Modernization - The Forum supports reform and modernization of the financial regulatory system to ensure the safety and soundness of financial institutions, promote financial systemic stability, and protect the varied interests of depositors, consumers, and investors.The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly to economic growth and job creation here at home.The Forum believes that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis.

H.R. 1450 Too-Big-to-Fail, Too-Big-to-Exist Act; H.R. 1553 to improve the examiniation of depository institutions; S 685 Too-Big-to Fail, Too-Big-to-Exist Act; S 727 A bill to improve the examination of depository institutions; S 731 and S 737-Basel III Study Bills; H.R.508 Terrorism Risk Insurance Act of 2002 Reauthorization Act of 2013; H.R. 613 Systemic Risk Mitigation Act; H.R. 677 Interaffiliate Swap Clarification Act; H.R. 688 Credit Union Small Business Jobs Creation Act; H.R. 749 Eliminate Privacy Notice Confusion Act; H.R. 992 Swaps Regulatory improvement Act; H.R. 1221 Basel II Capital Impact Study Act; H.R. 1256 Swap Jurisdiction Certainty Act; S 100 Terminating the Expansion of Too-Big-to Fail Act of 2013; S. 205 Responsible Consumer Financial Protection Regulations Act of 2013; S. 474 Swaps Regulatory Improvement Act; S. 635 Privacy Notice Modernization Act of 2013; S. 798-TBTF Act; H.R. 450-Bureau of Consumer Financial Protection Accountability Act; S. 1217-Housing Finance Reform and Taxpayer Protection Act of 2013; H.R. 2410-Agriculture, Rural Development, Food and Drug Administration and Related Agencies Appropriations Act, 2014; H.R. 3211, the "Mortgage Choice Act of 2013:' H.R. 3036, "To amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to specify when bank holding companies may be subject to certain enchanced supervision, and for other purposes".

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

Issues related to credit and debit cards, private student lending, bank regulation, consumer lending and consumer financial protection, amendments to FDI Act and GSE legislation, including: S113, S160, S451, S673, S685, S727, S798, S1018, S1048, S1159, and S1241

Client expense: $590,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Financial Regulatory Reform and Modernization - The Forum supports reform and modernization of the financial regulatory system to ensure the safety and soundness of financial institutions, promote financial systemic stability, and protect the varied interests of depositors, consumers, and investors.The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly to economic growth and job creation here at home. The Forumbelieves that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis.

H.R. 1450 Too-Big-to Fail, Too-Big-to Exist Act; H.R. 1553 To improve the examination of depository institutions; S.685 Too-Big-to-Fail, Too-Big-to Exist Act; S 727 A bill to improve the examination of depository institutions; S. 731 and S. 737 - Basel III Study Bills; H.R. 508 Terrorism Risk Insurance Act of 2002 Reauthorization Act of 2013; H.R. 613 Systemic Risk Mitigation Act; HR. 677 Interaffiliate Swap Clarification Act; H.R. 688 Credit Union Small Business Jobs Creation Act; H.R. 749 Eliminate Privacy Notice Confusion Act; H.R. 992 Swaps Regulatory improvement Act; H.R. 1221 Basel II Capital Impact Study Act; H.R. 1256 Swap Jurisdiction Certainty Act; S 100 Terminating the Expansion of Too-Big-to Fail Act of 2013; S. 205 Responsible Consumer Financial Protection Regulations Act of 2013; S. 474 Swaps Regulatory Improvement Act; S. 635 Privacy Notice Modernization Act of 2013; S. 798-TBTF Act; H.R. 450-Burwau of Consumer Financial Protection Accountability Act; S. 1217-Housing Finance Reform and Taxpayer Protection Act of 2013; H.R. 2410-Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2014; HR 3211, the Mortgage Choice Act of 2013; HR 3036, To amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to specify when bank holding companies may be subject to certain enhanced supervision, and for other purposes.

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

S. 25; Stop Unfair Giveaways and Restrictions Act of 2011; entire bill. S. 685; Free Sugar Act of 2013; entire bill. H.R. 1385; Free Market Sugar Act; entire bill. H.R. 1739; Free Sugar Act of 2013; entire bill.S. 954; Agriculture Reform, Food and Jobs Act of 2013; entire bill. H.R. 1741; Dairy Freedom Act; entire bill. Draft Biodiesel Tax Credit legislation.

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

Government targets: Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, SENATE, U.S. Trade Representative (USTR)

Issues related to credit cards, private student lending, bank holding company regulations, consumer lending and consumer financial protection, amendments to the FDIC Act and all GSE legislation, including: S113, S160, S451, S673, S685, S727, S798, S1018, S1048, S1159, S1241.

Client expense: $260,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Dodd-Frank Wall Street Reform and Consumer Protection Act Title 1, Financial Stability Title 2, Orderly Liquidation Authority Title 6, Improvements to Regs of Banks and Savings Association Holding Companies in Depository InstitutionsDodd-Frank Act continued Title 7, Regulation of OTC Swaps Market Title 9, Investor Protections and Improvements to Regulation of Securities Title 10, Bureau of Consumer Financial Protection S. 100 Terminating the Expansion of Too-big-To-Fail Act of 2013 S. 113 Know Before you Owe Private Student Loan Act of 2013 S. 114 To Amend Title 11, United States Code, With Respect to Certain Exceptions to Discharge in Bankruptcy S. 205 Responsible Consumer Financial Protection Regulations Act of 2013 S. 249 Responsible Homeowner Refinancing Act of 2013 S. 450 Financial Regulatory Responsibility Act of 2013 S. 451 Dodd-Frank Wall Street Reform and Consumer Protection Technical Corrections Act of 2013 S. 563 Jumpstart GSE Reform Act S. 685 A Bill to Address the Concept of Too Big To Fail With Respect to Certain Financial Entities H.R. 532 To Amend Title 11 of the United States Code to Modify the Dischargeability of Debts for Certain Educational Payments and Loans Covered Bonds legislative initiatives Basel III implementation Making Home Affordable Programs HAMP and HARP FHFA Real Estate Owned Disposition Initiative FHFA plan on single securitization platform Eminent Domain Seizure of Mortgage Loans Property Bill introduced by Senators' Corker and Warner entitled "Housing Finance Reform and Taxpayer Protection Act of 2013"y Assessed Clean Energy Programs

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

Dodd-Frank Wall Street Reform and Consumer Protection Act Title 1, Financial Stability Title 2, Orderly Liquidation Authority Title 6, Improvements to Regs of Banks and Savings Association Holding Companies in Depository InstitutionsDodd-Frank Act continued Title 7, Regulation of OTC Swaps Market Title 9, Investor Protections and Improvements to Regulation of Securities Title 10, Bureau of Consumer Financial Protection S. 100 Terminating the Expansion of Too-big-To-Fail Act of 2013 S. 113 Know Before you Owe Private Student Loan Act of 2013 S. 114 To Amend Title 11, United States Code, With Respect to Certain Exceptions to Discharge in Bankruptcy S. 205 Responsible Consumer Financial Protection Regulations Act of 2013 S. 249 Responsible Homeowner Refinancing Act of 2013 S. 450 Financial Regulatory Responsibility Act of 2013 S. 451 Dodd-Frank Wall Street Reform and Consumer Protection Technical Corrections Act of 2013 S. 563 Jumpstart GSE Reform Act S. 685 A Bill to Address the Concept of Too Big To Fail With Respect to Certain Financial Entities H.R. 532 To Amend Title 11 of the United States Code to Modify the Dischargeability of Debts for Certain Educational Payments and Loans Covered Bonds legislative initiatives Basel III implementation Making Home Affordable Programs HAMP and HARP FHFA Real Estate Owned Disposition Initiative FHFA plan on single securitization platform Eminent Domain Seizure of Mortgage Loans Property Assessed Clean Energy Programs Bill introduced by Senators' Corker and Warner entitled "Housing Finance Reform and Taxpayer Protection Act of 2013"

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

Met with House and Senate on issues related to derivatives and credit default swaps Met with House and Senate on implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 Met with House and Senate on large bank issuesH.R.613 - Systemic Risk Mitigation Act - all provisions H.R.677 - Inter-Affiliate Swap Clarification Act - all provisions H.R.992 - Swaps Regulatory Improvement Act - all provisions H.R.1256 - Swap Jurisdiction Certainty Act - all provisions H.R.1341 - Financial Competitive Act of 2013 - all provisions S.169 - I-Squared Act of 2013 - all provisions S.296 - Uniting American Families Act of 2013 - all provisions Met with House and Senate on equities market structure reform H.R.2739 - Retail Investors Protection Act - all provisions S.798 - TBTF Act - all provisions S.1450 - The Too Big To Fail, Too Big to Exist Act - all provisions S.685 - The Too Big to Fail, Too Big to Exist Act - all provisions S.1217 - The Housing Finance Reform and Taxpayer Protection Act - all provisions

Client expense: $1,450,000 · Firm income: Not reported

H.R.1450 Too-Big-to-Fail, Too-Big-to-Exist Act; H.R.1553 To improve the examination of depository institutions; S.685 Too-Big-to-Fail, Too-Big-to-Exist Act; S.727 A bill to improve the examination of depository institutions; S.731 and S.737 - Basel III Study Bills; H.R.508 Terrorism Risk Insurance Act of 2002 Reauthorization Act of 2013; H.R.613 Systemic Risk Mitigation Act; H.R.677 Interaffiliate Swap Clarification Act; H.R.688 Credit Union Small Business Jobs Creation Act; H.R.749 Eliminate Privacy Notice Confusion Act; H.R.992 Swaps Regulatory improvement Act; H.R.1221 Basel II Capital Impact Study Act; H.R.1256 Swap Juristiction Certainty Act; S.100 Terminating the Expansion of Too-Big-To-Fail Act of 2013; S. 205 Responsible Consumer Financial Protection Regulations Act of 2013; S.474 Swaps Regulatroy Improvement Act; S.635 Privacy Notice Modernization Act of 2013; S.798-TBTF Act; H.R.450-Bureau of Consumer Financial Protection Accountability Act; S.1217-Housing Finance Reform and Taxpayer Protection Act of 2013; H.R.2410-Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2014.

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

Government targets: Commodity Futures Trading Commission (CFTC), Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, White House Office

S. 25; Stop Unfair Giveaways and Restrictions Act of 2011; entire bill. S. 685; Free Sugar Act of 2013; entire bill. H.R. 1385; Free Market Sugar Act; entire bill. H.R. 1739; Free Sugar Act of 2013; entire bill.S. 954; Agriculture Reform, Food, and Jobs Act of 2013; entire bill. H.R. 1741; Dairy Freedom Act; entire bill. Draft Biodiesel Tax Credit legislation.

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

Government targets: Agriculture, Dept of (USDA), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, SENATE, U.S. Trade Representative (USTR)

HR 613: A bill to establish a market-based trigger to determine the capital adequacy of bank holding companies and decrease systemic risk, and for other purposes; provisions related to banking structure. HR 624: A bill to provide for the sharing of certain cyber threat intelligence community and cyber security entities, and for other purposes; provisions related to cyber security.HR 677: A bill to exempt inter-affiliate swaps from certain regulatory requirements put in place by the Dodd-Frank Wall Street Reform and Consumer Act; provisons related to Derivatives Regulation HR 992: A bill to amend provisions in section 716 of the Dodd-Frank Wall Street Reform and Consumer Protection Act relating to Federal assistance for swaps entities; provisons related to Derivatives Regulation HR 1256: A bill to direct the Securities and Exchange Commission and the Commodity Futures Trading commission to jointly adopt rules setting forth the application to cross-border swaps transactions of certain provisions relating to swaps that were enacted as part of Dodd-Frank; provisons related to Derivatives Regulation HR 1261: A bill to amend the Truth in Lending Act to establish fair and transparent practices related to the marketing and provision of overdraft coverage programs at depository institutions; provisons related to Consumer Protections HR 1450: A bill to address the concept of "Too Big to Fail" with respect to certain financial entities.; provisons related to Banking Structure S 21: A bill to security the United States against Cyber attack, to improve communication and collaboration between the private sector and the Federal Government, to enhance American competitiveness and create jobs in the information technology industry, and to protect the identities and sensitive information of American citizens and businesses; provisons related to Cyber Security S 100: A bill to amend the Financial Stability Act of 2010 to repeal certain designation authority of the Financial Stability Oversight Council, to repeal the Payment, Clearing, and Settlement Supervision Act of 2010, and for other purposes; provisons related to payments S 172: A bill to amend the Truth in Lending Act to address certain issues related to the extension of consumer credit S 187: A bill to amend the Truth in Lending Act to prohibit the distribution of any check or other negotiable instrument as part of a solicitation by a creditor for an extension of credit, to limit the liability of consumer in conjunction with such solicitations. S 450: A bill to require enhanced economic analysis and justification of regulations proposed by certain Federal banking, housing, security, and commodity regulators, and for other purposes; provisons related to Regulatory Rule Making S 451: A bill to make technical corrections to Dodd-Frank S 474: A bill to amend provisions in section 716 of the Dodd-Frank Wall Street Reform and Consumer Protection Act relating to Federal assistance for swaps entities; provisons related toDerivatives Regulation S. 673: A bill to amend the Truth in Lending Act to establish a national usury rate for consumer credit transactions. S 685: A bill to address the concept of "Too Big to Fail" with respect to certain financial entities; ; provisons related to Banking Structure Orderly Liquidation Authority- Implementation of Title II of Dodd Frank - Bank Resolution DFA Title I - Implementation of Title I of Dodd Frank - Bank Resolution Capital Requirements - Implementation of Basel Agreement - Bank Regulatory Capital Enhanced Prudential RequirementsImplementation of 165 of Dodd-Frank - SIFI Regulation Payments - Regulation of payments and implementation of Dodd-Frank - Payments System HR 634: A bill to provide end user exemptions from certain provisions of the Commodity Exchange Act and the Securities Exchange Act of 1934, and for other purposes HR 756: A bill to advance cybersecurity research, development, and technical standards, and for other purposes HR 850: A bill to impose additional human rights and economic and financial sanctions with respect to Iran, and for other purposes HR 1121: A bill to protect cyber privacy and for other purposes HR 1341: A bill to require the Financial Stability Oversight Council to conduct a study of the likely effects of the differences between the United States and other jurisdictions in implementing the derivatives credit valuation adjustment capital requirementHR 1687: A bill to provide for the imposition of sanctions with respect to foreign persons responsible for or complicit in ordering , controlling, or otherwise directing, the commission of serious human rights abuses against citizens of ALBA countries, and for other purposes. HR 1750: A bill to enhance the ability of community financial institutions to foster economic growth and serve their communities, boost small businesses, increase individual savings, and for other purposes HR 2266: A bill to amend the Dodd-Frank Wall Street Reform and Consumer Protection act to require certain systemically important entities to account for the financial benefit they receive as a result of the expectations on the part of shareholders, creditors, and counterparties of such entities that the Government will shield them from losses in the event of failure HR 2295: A bill to require the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency to conduct an empirical impact study on proposed rules relating to the Internal Basel III agreement on general risk-based capital requirements, an they apply to smaller financial institutions HR 2547: A bill to determine appropriate risk based capital requirements for community, mid-size, and regional institutions S 731: A bill to require the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency to conduct an empirical impact study on proposed rules relating to the Internal Basel III agreement on general risk-based capital requirements, an they apply to community banks. S 737: A bill to require the Federal banking agencies to conduct a quantitative impact study on the cumulative effect of the Basel III framework. S. 798: A bill to address equity capital requirements for financial institutions, bank holding companies, subsidiaries, and affiliates, and for other purposes S. 892: A bill to amend the Iran Threat Reduction and Syria Human Rights Act of 2012 to impose sanctions with respect to certain transactions in foreign currencies, and for other purposes S. 1001: A bill to impose sanctions with respect to the Government of Iran

Issues related to credit cards, private student lending, bank holding company regulations, consumer lending and consumer financial protection, amendments to the FDIC ACT and all GSE legislation, including: S113, S160, S451, S673, S685, S727, S798, S1018, S1048, S1159, S1241

Client expense: $380,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Financial Regulatory Reform and Modernization - The Forum supports reform and modernization of the financial regulatory system to ensure the safety and soundness of financial institutions, promote financial systemic stability, and protect the varied interests of depositors, consumers, and investors.The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly toeconomic growth and job creation here at home.

Dodd-Frank Wall Street Reform and Consumer Protection Act Title 1, Financial Stability Title 2, Orderly Liquidation Authority Title 6, Improvements to Regs of Banks and Savings Association Holding Companies in Depository InstitutionsDodd-Frank Act continued Title 7, Regulation of OTC Swaps Market Title 9, Investor Protections and Improvements to Regulation of Securities Title 10, Bureau of Consumer Financial Protection S. 100 Terminating the Expansion of Too-big-To-Fail Act of 2013 S. 113 Know Before you Owe Private Student Loan Act of 2013 S. 114 To Amend Title 11, United States Code, With Respect to Certain Exceptions to Discharge in Bankruptcy S. 205 Responsible Consumer Financial Protection Regulations Act of 2013 S. 249 Responsible Homeowner Refinancing Act of 2013 S. 450 Financial Regulatory Responsibility Act of 2013 S. 451 Dodd-Frank Wall Street Reform and Consumer Protection Technical Corrections Act of 2013 S. 563 Jumpstart GSE Reform Act S. 685 A Bill to Address the Concept of Too Big To Fail With Respect to Certain Financial Entities H.R. 532 To Amend Title 11 of the United States Code to Modify the Dischargeability of Debts for Certain Educational Payments and Loans Covered Bonds legislative initiatives Basel III implementation Making Home Affordable Programs HAMP and HARP FHFA Real Estate Owned Disposition Initiative FHFA plan on single securitization platform Eminent Domain Seizure of Mortgage Loans Property Assessed Clean Energy Programs Bill introduced by Senators' Corker and Warner entitled "Housing Finance Reform and Taxpayer Protection Act of 2013"

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

Dodd-Frank Wall Street Reform and Consumer Protection Act Title 1, Financial Stability Title 2, Orderly Liquidation Authority Title 6, Improvements to Regs of Banks and Savings Association Holding Companies in Depository InstitutionsDodd-Frank Act continued Title 7, Regulation of OTC Swaps Market Title 9, Investor Protections and Improvements to Regulation of Securities Title 10, Bureau of Consumer Financial Protection S. 100 Terminating the Expansion of Too-big-To-Fail Act of 2013 S. 113 Know Before you Owe Private Student Loan Act of 2013 S. 114 To Amend Title 11, United States Code, With Respect to Certain Exceptions to Discharge in Bankruptcy S. 205 Responsible Consumer Financial Protection Regulations Act of 2013 S. 249 Responsible Homeowner Refinancing Act of 2013 S. 450 Financial Regulatory Responsibility Act of 2013 S. 451 Dodd-Frank Wall Street Reform and Consumer Protection Technical Corrections Act of 2013 S. 563 Jumpstart GSE Reform Act S. 685 A Bill to Address the Concept of Too Big To Fail With Respect to Certain Financial Entities H.R. 532 To Amend Title 11 of the United States Code to Modify the Dischargeability of Debts for Certain Educational Payments and Loans Covered Bonds legislative initiatives Basel III implementation Making Home Affordable Programs HAMP and HARP FHFA Real Estate Owned Disposition Initiative FHFA plan on single securitization platform Eminent Domain Seizure of Mortgage Loans Property Bill introduced by Senators' Corker and Warner entitled "Housing Finance Reform and Taxpayer Protection Act of 2013"y Assessed Clean Energy Programs

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

S 685, Too Big to Fail, Too Big to Exist Act, all provisions; HR 624, Cyber Intelligence Sharing Protection Act (CISPA); all provisions; Dodd-Frank Act implementation issues; capital issues.

Client expense: $1,450,000 · Firm income: Not reported

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

HR 613: A bill to establish a market-based trigger to determine the capital adequacy of bank holding companies and decrease systemic risk, and for other purposes; provisions related to banking structure. HR 624: A bill to provide for the sharing of certain cyber threat intelligence community and cyber security entities, and for other purposes; provisions related to cyber security.HR 677: A bill to exempt inter-affiliate swaps from certain regulatory requirements put in place by the Dodd-Frank Wall Street Reform and Consumer Act; provisons related to Derivatives Regulation HR 992: A bill to amend provisions in section 716 of the Dodd-Frank Wall Street Reform and Consumer Protection Act relating to Federal assistance for swaps entities; provisons related to Derivatives Regulation HR 1256: A bill to direct the Securities and Exchange Commission and the Commodity Futures Trading commission to jointly adopt rules setting forth the application to cross-border swaps transactions of certain provisions relating to swaps that were enacted as part of Dodd-Frank; provisons related to Derivatives Regulation HR 1261: A bill to amend the Truth in Lending Act to establish fair and transparent practices related to the marketing and provision of overdraft coverage programs at depository institutions; provisons related to Consumer Protections HR 1450: A bill to address the concept of "Too Big to Fail" with respect to certain financial entities.; provisons related to Banking Structure S 21: A bill to security the United States against Cyber attack, to improve communication and collaboration between the private sector and the Federal Government, to enhance American competitiveness and create jobs in the information technology industry, and to protect the identities and sensitive information of American citizens and businesses; provisons related to Cyber Security S 100: A bill to amend the Financial Stability Act of 2010 to repeal certain designation authority of the Financial Stability Oversight Council, to repeal the Payment, Clearing, and Settlement Supervision Act of 2010, and for other purposes; provisons related to payments S 172: A bill to amend the Truth in Lending Act to address certain issues related to the extension of consumer credit S 187: A bill to amend the Truth in Lending Act to prohibit the distribution of any check or other negotiable instrument as part of a solicitation by a creditor for an extension of credit, to limit the liability of consumer in conjunction with such solicitations. S 450: A bill to require enhanced economic analysis and justification of regulations proposed by certain Federal banking, housing, security, and commodity regulators, and for other purposes; provisons related to Regulatory Rule Making S 451: A bill to make technical corrections to Dodd-Frank S 474: A bill to amend provisions in section 716 of the Dodd-Frank Wall Street Reform and Consumer Protection Act relating to Federal assistance for swaps entities; provisons related toDerivatives Regulation S. 673: A bill to amend the Truth in Lending Act to establish a national usury rate for consumer credit transactions. S 685: A bill to address the concept of "Too Big to Fail" with respect to certain financial entities; ; provisons related to Banking Structure Orderly Liquidation Authority- Implementation of Title II of Dodd Frank - Bank Resolution DFA Title I - Implementation of Title I of Dodd Frank - Bank Resolution Capital Requirements - Implementation of Basel Agreement - Bank Regulatory Capital Enhanced Prudential RequirementsImplementation of 165 of Dodd-Frank - SIFI Regulation Payments - Regulation of payments and implementation of Dodd-Frank - Payments System

Dodd-Frank Wall Street Reform and Consumer Protection Act Title 1, Financial Stability Title 2, Orderly Liquidation Authority Title 6, Improvements to Regs of Banks and Savings Association Holding Companies in Depository InstitutionsDodd-Frank Act continued Title 7, Regulation of OTC Swaps Market Title 9, Investor Protections and Improvements to Regulation of Securities Title 10, Bureau of Consumer Financial Protection S. 100 Terminating the Expansion of Too-big-To-Fail Act of 2013 S. 113 Know Before you Owe Private Student Loan Act of 2013 S. 114 To Amend Title 11, United States Code, With Respect to Certain Exceptions to Discharge in Bankruptcy S. 205 Responsible Consumer Financial Protection Regulations Act of 2013 S. 249 Responsible Homeowner Refinancing Act of 2013 S. 450 Financial Regulatory Responsibility Act of 2013 S. 451 Dodd-Frank Wall Street Reform and Consumer Protection Technical Corrections Act of 2013 S. 563 Jumpstart GSE Reform Act S. 685 A Bill to Address the Concept of Too Big To Fail With Respect to Certain Financial Entities H.R. 532 To Amend Title 11 of the United States Code to Modify the Dischargeability of Debts for Certain Educational Payments and Loans Covered Bonds legislative initiatives Basel III implementation Making Home Affordable Programs HAMP and HARP FHFA Real Estate Owned Disposition Initiative FHFA plan on single securitization platform Eminent Domain Seizure of Mortgage Loans Property Assessed Clean Energy Programs

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

Dodd-Frank Wall Street Reform and Consumer Protection Act Title 1, Financial Stability Title 2, Orderly Liquidation Authority Title 6, Improvements to Regs of Banks and Savings Association Holding Companies in Depository InstitutionsDodd-Frank Act continued Title 7, Regulation of OTC Swaps Market Title 9, Investor Protections and Improvements to Regulation of Securities Title 10, Bureau of Consumer Financial Protection S. 100 Terminating the Expansion of Too-big-To-Fail Act of 2013 S. 113 Know Before you Owe Private Student Loan Act of 2013 S. 114 To Amend Title 11, United States Code, With Respect to Certain Exceptions to Discharge in Bankruptcy S. 205 Responsible Consumer Financial Protection Regulations Act of 2013 S. 249 Responsible Homeowner Refinancing Act of 2013 S. 450 Financial Regulatory Responsibility Act of 2013 S. 451 Dodd-Frank Wall Street Reform and Consumer Protection Technical Corrections Act of 2013 S. 563 Jumpstart GSE Reform Act S. 685 A Bill to Address the Concept of Too Big To Fail With Respect to Certain Financial Entities H.R. 532 To Amend Title 11 of the United States Code to Modify the Dischargeability of Debts for Certain Educational Payments and Loans Covered Bonds legislative initiatives Basel III implementation Making Home Affordable Programs HAMP and HARP FHFA Real Estate Owned Disposition Initiative FHFA plan on single securitization platform Eminent Domain Seizure of Mortgage Loans Property Assessed Clean Energy Programs

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