Credit Union Residential Loan Parity Act
Legislative Progress
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vs 3,548 other S bills in the 114th — cohort avg 43d
Credit Union Residential Loan Parity Act Amends the Federal Credit Union Act to revise the definition of "member business loan," which currently excludes an extension of credit fully secured by a lien on a 1- to 4-family dwelling that is a member's primary residence. Removes the condition that the dwelling be a member's primary residence, and so denying eligibility for a member business loan to any requested extension of credit that would be fully secured by a lien on a 1- to 4-family dwelling, regardless of whether it is or is not the member's primary residence. Declares that this Act does not preclude the National Credit Union Administration from treating an extension of credit fully secured by a lien on a 1- to 4-family dwelling that is not a member's primary residence as a member business loan for purposes other than certain member business loan limitation requirements under the Act.
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Filing registrants (6)
Read twice and referred to the Committee on Banking, Housing, and Urban Affairs. (Sponsor introductory remarks on measure: CR S3243; text of measure as introduced: CR S3243)
Introduced in Senate
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Sources: Congress.gov
Issues related to credit union operations Issues related to credit union field of membership Issues related to credit union service organizations Issues related to vacancies on the National Credit Union Administration (NCUA) Board Issues related to NCUAs low income designation regulations Issues related to NCUA examination procedures Issues related to NCUAs regulation regarding its regulatory flexibility program Issues related to NCUAs proposed rule regarding emergency liquidity Issues related to NCUAs rulemaking process Issues related to material loss reports of the NCUA Office of Inspector General Issues related to the authority of the CFPB to exempt credit unions from its rulemaking Issues related to the CFPB proposal related to remittances and international wire transfers Issues related to the proposed CFPB form on RESPA/TILA Issues related to CFPBs Leadership Structure and Installing a Board Rather than Director Issues related to funding the CFPB through the Appropriations Process Issues related to increasing the CFPB Examination Threshold Issues related to conducting a cost-benefit analysis of all CFPB Proposals Issues related to codifying the CFPBs Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to standardizing the definition of mortgage originator Issues related to overdraft protection and check ordering practices Issues related to mortgage servicing Issues related to mortgage loan originator compensation and qualifications Issues related to high-cost mortgage loans (HOEPA) Issues related to the CFPBs proposed rule regarding qualified mortgage / ability to repay Issues related to reverse mortgages Issues related to the Financial Accounting Standards Board (FASB) Issues related to mark-to-market accounting Issues related to private equity standards Issues related to the implementation of the Unlawful Internet Gambling Prohibition Act Issues related to data and cyber security Issues related to mobile banking and mobile payments Issues related to the oversight of the Federal Housing Administration Issues related to USDA Rural Development Loan program Issues related to identity theft and fraud reduction Issues related to student lending Issues related to the Federal Home Loan Bank System Issues related to short term lending products and advance deposit products Issues related to patent reform Issues related to Federal Credit Union bylaws Issues relating to home-based credit unions Issues related to NCUAs risk-based capital proposal Issues related to NCUAs proposed rule on securitization Issues related to NCUAs regulatory review process Issues related to credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union by-laws Issues related to credit unions incidental powers Issues related to credit unions ability to offer prepaid cards Issues related to Ginnie Mae capital Issues related to credit union service to marijuana businesses Issues related to financial literacy Issues related to the Department of Justices investigation entitled, Operation Choke Point Issues related to membership eligibility in the Federal Home Loan Bank System. Issues related to the Department of Defense proposal regarding Credit Extending to Service Members under MLA Issues related to the Economic Growth and Regulatory Paperwork Reduction Act process Issues related to indirect auto lending Issues related to fixed assets Issues related to merchant data breaches Issues related to the payments system Issues related to FHFA proposed rules and FHLB eligibility for credit unions Issues related to Federal Reserve Regulatory D Issues related to 1-4 Family Non-Owner Occupied Residential Loan Treatment as Residential Rather than Business Loans Issues related to the use of Eminent Domain to Seize Performing Mortgage Loans Issues related to Housing Finance Reform Issues related to the implementation of the remittances provisions in the Dodd-Frank Act Issues related to NCUAs proposal rule on Member Business Lending Issues related to NCUAs proposed rule on Interest on Lawyer Trust Accounts (IOLTA) Issues related to credit union service to unbanked and underbanked consumers Issues related to the United States Postal Service Office of Inspector General report related to role of the postal service in financial services Issues related to the Feds implementation of same-day ACH Issues related to the regulation of corporate credit unions Issues related to the CFPBs proposed regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the payday, vehicle title, and similar lending Issues related to the CFPBs consumer complaint database Issues related to NCUAs Fixed Assets rule Issues related to NCUAs definition of small entity Issues related to NCUA's Proposed Rule on Member Business Lending Issues related to the Department of Labor's Proposed Rule on the Definition of Fiduciary Issues related to the Telephone Consumer Protection Act Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements Issues related to the Department of Labor's Proposed Overtime Eligibility rule Issues related to credit union conversions Issues related to the CFPB's proposal on arbitration Issues related to secure payments Issues related to credit union call report modernization H.R. 9, the Innovation Act, all provisions H.R. 22, the FAST Act, Title LXXV, provisions related to privacy notice requirements; Title LXXXII, provisions related to the eligibility of privately insured credit unions to join a Federal Home Loan Bank; Title LXXXIX, provisions related to the designation of rural areas by the Consumer Financial Protection Bureau H.R. 185, Regulatory Accountability Act of 2015 H.R. 299, the Capital Access for Small Community Financial Institutions Act of 2015, all provisions H.R. 527, the Small Business Regulatory Flexibility Improvements Act of 2015 H.R. 601, the Eliminate Privacy Notice Confusion Act, all provisions H.R. 650, Preserving Access to Manufactured Housing Act, all provision H.R. 685, the Mortgage Choice Act, all provisions H.R. 766, Financial Institution Consumer Protection Act, all provisions H.R. 957, the Bureau of Consumer Financial Protection Inspector General Reform Act, all provisions H.R. 989, the Capital Access for Small Businesses Jobs Creation Act, all provisions H.R. 1090, Retail Investor Protection Act, all provisions H.R. 1176, the NCUA Budget Transparency Act, all provisions H.R. 1188, the Credit Union Small Business Jobs Creation Act, all provisions H.R. 1195, the Bureau of Consumer Financial Protection Advisory Boards Act, all provisions H.R. 1210, the Portfolio Lending and Mortgage Access Act, H.R. 1233, the Community Lending Enhancement and Regulatory Relief Act of 2015 H.R. 1259, the Helping Expand Lending Practices in Rural Communities Act, all provisions H.R. 1263, Consumer Financial Protection Safety and Soundness Improvement Act of 2015 H.R. 1265, the Bureau Advisory Commission Transparency Act, all provision H.R. 1266, the Financial Products Safety Commission Act of 2015 H.R. 1408, requiring a study of the capital requirements for mortgage servicing assets H.R. 1422, the Credit Union Residential Loan Parity Act H.R. 1480, the SAFE Confidentiality and Privilege Enhancement Act H.R. 1523, Community Bank Access to Capital Act of 2015 H.R. 1529, the Community Institution Mortgage Relief Act Discussion Draft, Data Security and Breach Notification Act of 2015 H.R. 1660, the Federal Savings Association Charter Flexibility Act, all provisions H.R. 1941, the Financial Institution Examination Fairness and Reform Act H.R. 2205, the Data Security Act H.R. 2213, to provide for a temporary safe harbor from the enforcement of integrated disclosure requirements for mortgage loan transactions under the Real Estate Settlement Procedures Act of 1974 and the Truth in Lending Act, and for other purposes. H.R. 2287, the National Credit Union Administration Budget Transparency Act H.R. 2473, the Preserving Capital Access and Mortgage Liquidity Act H.R. 2769, the Risk-Based Capital Study Act, all provisions H.R. 2896, the Taking Account of Institutions with Low Operation Risk (TAILOR) Act H.R. 3192, the Homebuyer Assistance Act, all provisions H.R. 4638, the Senior $afe Act, all provisions H.R. 4893, the Risk Management and Homeowner Stability Act, all provisions H.R. 4997, the Home Mortgage Disclosure Adjustment Act, all provisions H.R. 5465, a bill to repeal section 1075 of the Consumer Financial Protection Act of 2010 relating to rules for payment card transactions, all provisions H.R. 5983, the Financial CHOICE Act, all provisions S. 423, the Privacy Notice Modernization Act, all provisions S. 482, the Consumer Financial Protection Bureau Examination Reporting Threshold Act of 2015, all provisions S. 774 Financial Institutions Examination Fairness and Reform Act, all provisions S. 871, the Helping Expand Lending Practices in (HELP) Rural Communities Act S. 924, the National Credit Union Administration Budget Transparency Act S. 961, the Data Security Act S. 1367, a bill to amend the Federal Home Loan Bank Act with respect to membership eligibility of certain institutions S. 1440, the Credit Union Residential Loan Parity Act S. 1484, the Financial Regulatory Improvement Act, Title I S. 2216, the Senior$afe Act, all provisions The Heck-Stivers Amendment to H.R. 1735, the National Defense Authorization Act, related to the Department of Defenses MLA Database Discussion draft of the Financial Creating Hope and Opportunity for Investors, Consumers and Entrepreneurs (CHOICE) Act, all provisions
Client expense: $1,090,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Consumer Financial Protection Bureau (CFPB), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), SENATE, Small Business Administration (SBA), Treasury, Dept of
2016 · fourth_quarter · Financial Institutions/Investments/Securities
Supplemental capital issues, regulatory issues for credit unions and tax exemption status: HR 185; HR 957; HR 1176; HR 1188; HR 1266; HR 1422; HR 1486; HR 1529; HR 1550; HR 1660; HR 1941; HR 2099; HR 2213; HR 2473; HR 2769;HR 2896; HR 3557; HR 3738; HR 3808; HR 3857; HR 4099; HR 4210; HR 4248; HR 4647; HR 4894; HR 4913; HR 4997; HR 5112; HR 5211; HR 5413; HR 5419; HR 5453; HR 5465; HR 5490; HR 5491; HR 5521; HR 5522; HR 5523; HR 5527; HR 5569; HR 5724; HR 5869; HR 5991; HR 6118; HR 6162; HR 6244; HR 6266; HR 6392; S. 423; S. 482; S. 726; S. 774; S. 924; S. 970; S. 1383; S. 1440; S. 1484; S. 1491; S. 2038; S. 2216; S. 2315; S. 2663; S. 2722; S. 2760; S. 2790; S. 2995; 2.3083; S. 3153; S. 3196; S. 3215; S. 3219; S. 3321; data security and cybersecurity; patent reform; FHLB membership rules; CFPB and FSOC reform; and GSE reform.
Client expense: Not reported · Firm income: $50,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2016 · fourth_quarter · Banking
Consumer Financial Protection Bureaus (CFPB) Notice and Request for Comment on Web-Based Quantitative Testing Point of Sale/ATM (POS/ATM) Overdraft Disclosure Forms; Comments responding to request for information on the FHFAs proposed collection of information relating to the NSEMB; Comments on Regulatory Impact Assessment and Initial Regulatory Flexibility Analysis, RIN 1506-AB25; Concerns with CFPB future payday lending rulemakings; payday lending as related to the CFPB Proposals; H.R. 3192: Homebuyers Assistance Act; H.R. 2769: Risk-Based Capital Study Act; National Credit Union Administrations (NCUA) risk-based capital proposal; H.R. 2205: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; NCUAs budget; H.R. 1176: NCUA Budget Transparency Act/ GAO Study of NCUA budgeting practices; H.R. 1188: Credit Union Small Business Jobs Creation Act/ raising MBL cap; H.R. 1195: Bureau of Consumer Financial Protection Advisory Boards Act; H.R. 1210: Portfolio Lending and Mortgage Access Act; H.R. 2473: Preserving Capital Access and Mortgage Liquidity Act of 2015; H.R. 2896: the TAILOR Act of 2015; S. 754: Cyber Security Information Sharing Act; NAFCUs Five Point Plan for Regulatory Relief (capital reforms for credit unions; field of membership improvements for credit unions; reduced consumer financial protection bureaus on credit unions; operational improvements for credit unions; 21st century data security standards); Regulatory relief for credit unions; Impact of Federal Regulations on Credit Unions; S. 961: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; NCUAs efforts to allow credit unions to better serve rural areas; H.R. 1259: Helping Expand Lending Practices in Rural Communities Act; CFPBs interim final rule amending Regulation Z; H.R. 1261: Bureau of Consumer Financial Protection Accountability Act/ Subjects CFPB to Congressional appropriations process; S. 774: Financial Institutions Examination Fairness and Reform Act; S. 871: HELP Rural Communities Act of 2015/ CFPB Rural Definition; H.R. 685: Mortgage Choice Act of 2015/ Points and Fees; H.R. 1408: Mortgage Servicing Asset Capital Requirements Act; H.R. 1422: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; H.R. 1529: Community Institution Mortgage Relief Act of 2015; H.R. 1941: Financial Institutions Examination Fairness and Reform Act; Regulatory Burdens; Qualified Mortgage Rule; S. 1484: Financial Regulatory Improvement Act; Federal Credit Union Act; S. 2028: A bill to amend the Federal Credit Union Act, to advance the ability of credit unions to promote small business growth and economic development opportunities, and for other purposes; H.R. 3738: the Office of Financial Research Accountability Act of 2015; H.R. 3557: the FSOC Transparency and Accountability Act; H.R. 1660: the Federal Savings Association Charter Flexibility Act; Improve the federal charter of credit unions through the FCU Act; H.R. 989: Capital Access for Small Businesses and Jobs Act/ Supplemental Capital; H.R. 1133: To exclude extensions of credit made to veterans from the definition of a member business loan under the Federal Credit Union Act; NCUA proposed rulemaking on a federal insured credit unions member business lending; NCUAs exam scheduling policy; NAFCUs Top Ten Regulations for Eliminate of Amend (improve process for credit unions seeking changes to their field of membership; provide more meaningful exemptions for small institutions; Dodd-Frank 1022 Authority; expand credit union investment authority; allowing more transfers per month from savings accounts per Federal Reserve Regulation D; flexibility for credit unions making member business loans; NCUAs member business lending rule: update requirement to disclose account numbers to protect privacy of members; update advertising requirements for loan products and share accounts; Accuracy of advertising and notice of insured status; seek improvements to the NCUA Central Liquidity Facility (CLF); CLF information collection; CLF modernization to obtain flexibility for federal credit unions to determine their choice of law; update simplify and make improvements to regulations governing check processing funds); S. 423: Privacy Notice Modernization Act of 2015; H.R. 22: the Surface Transportation Reauthorization and Reform Act of 2015; NCUAs proposed Field of Membership Amendments; H.R. 2995: Financial Services and General Government Appropriations Act; Require the CFPB to conduct a fair, comprehensive study before adopting a rule that would restrict arbitration and open the door to abusive class actions; prevent arbitration restrictions; NCUA third party vendor authority; CFPB request for approval under the Paperwork Reduction Act to conduct a national web-based survey relative to overdraft protection services; CFPB consumer complaint narrative database; CFPB and the student loan servicing market; Student Loan Borrower Communication ;CFPB integration of the Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) disclosures, consider good faith efforts to comply with TRID; financial regulators must level the playing field and promulgate rules that require non-traditional market lenders to meet basic consumer protection requirements such as those of TILA, underwriting standards for loans, and applicable state usury laws; NCUAs usury ceiling under the FCU Act; FSOC should facilitate regulatory coordination among its member regulators; preserve the credit union tax exemption; regulatory relief including CFPB using their exemption authority more; Housing Finance Reform - it is vital that credit unions continue to have unfettered access to the secondary mortgage market and any reforms should have emphasis on fair pricing that reflects loan quality rather than quantity; Department of Labors proposed changes to the Fair Labor Standards Act for certain full-time salaried works to be eligible for overtime protections; Federal Communication Commission clarification for free end user calls made by financial institutions; Federal Communication Commission regarding clarifications to the interpretations of the Telephone Consumer Protection Act; FCCs Declaratory Ruling and Order on TCPA; H.R. 1155: the Searching for and Cutting Regulations that are unnecessarily Burdensome (SCRUB) Act; prepaid cards - CFPB efforts to ensure that consumers using prepaid products are sufficiently informed and protected - they should find appropriate balance between adequate consumer protection and allowing consumers access to products they demand; compliance burdens related to CFPB amendments to Regulation C, HMDA; Uniform Residential Loan Application (URLA); Periodic Statements for Borrowers who have filed for bankruptcy; Statement production systems and CFPBs servicing regulations; Small Business Administration SBA 7(a) business loan program; H.R. 2499: Veterans Entrepreneurship Act of 2015; FY 2016 Financial Services and General Government Appropriations bill; H.R. 427: Regulations for the Executive in Need of Scrutiny Act of 2015; Improve agency use of regulatory guidance; Protect responsible overdraft services; Changes to requirements under the Home Mortgage Disclosure Act; H.R. 957: Bureau of Consumer Financial Protection Inspector General Reform Act; Reform of Fannie Mae and Freddie Mac; Credit risk-guarantee fees; Military Lending Act; H.R. 1735: National Defense Authorization Act for Fiscal Year 2016; Cost-benefit analysis at federal regulatory agencies; Regulatory coordination; Regulations related to remittance transfers; Legal opinion letters at the CFPB and NCUA; H.R. 9: Innovation Act; H.R. 185: Regulatory Accountability Act of 2015; H.R. 527: Small Business Regulatory Flexibility Improvements Act of 2015; H.R. 650: Preserving Access to Manufactured Housing Act; H.R. 766: Financial Institution Customer Protection Act/ Ending Operation Choke Point; H.R. 1262: Consumer Right to Financial Privacy Act of 2015; H.R. 1263: Consumer Financial Protection Safety and Soundness Improvement Act/ Changes veto authority of the Financial Stability Oversight Council; H.R. 1265: Bureau Advisory Commission Transparency Act/ Making credit union advisory council meetings public; H.R. 1266: Financial Product Safety Commission Act/ Replacing CFPB Director with Commission; H.R. 1309: Systemic Risk Designation Improvement Act of 2015; S. 881: Comprehensive Regulatory Review Act of 2015; S. 924: To require public hearings on NCUA's budget; S. 1137: PATENT Act; S. 1440: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; Ensure an Effective Payments system; Fairness under FCC ruling on autodialing and FCC oversight; Telephone Consumer Protection Act; modernize online lending laws and regulations; give NCUA greater flexibility with credit union lending including the ability to establish longer maturities for certain loans; preventing g-fees charged by Fannie and Freddie from being used as funding offset; NCUA 18-month Exam Cycle; Military Lending Act Database; Credit Losses Accounting Standard; FASB Accounting Standards; CFPBs expansion of data collection under Reg C, Privacy protections for data collected by CFPB; NIST notice and request for information on views on the Framework for Improving Critical Infrastructure Cybersecurity; Comments on Notice of proposed rulemaking regarding field of membership and chartering; CBSA population limit, combined statistical area, well defined local communities, rural population limits, multiple common bond charters, underserved areas, TIP charters; CFPB information collection on compliance costs and other effects of regulation; Duty to serve underserved markets; interchange rates as related to the Durbin Amendment to Dodd-Frank; Repeal Durbin Amendment; H.R. 5465 - to repeal Durbin Amendment; Federal Reserves EGRPRA review process; FHFAs principal reduction consideration; FFIEC Cybersecurity Assessment Tool; FFIEC proposed revision to the Uniform Interagency Consumer Compliance Rating System; Department of Labor Fiduciary Rule, Department of Labor overtime Rule; Administrative Procedures Act; Regulatory Flexibility for credit unions; Promote Consumer Protection and Financial Literacy; Financial Technology (FinTech); FinTech and online marketplace lending; Transparency for NCUAs Overhead Transfer Rate methodology; Transparency for NCUAs Operating Fee methodology; FY 2017 Financial Services and General Government Appropriations Bill; Community Development Financial Institution funding (CDFI); CDFI certification and reporting requirements; Dept. of Treasurys National Strategy for financial literacy and education; NCUAs information collection on investment and deposit activities; allow credit unions to purchase loans from other originators for purposes of issuing securities; mortgage servicing rights; extend exemption for consumer credit cards from MLA Rule requirements; Secondary Capital for low-income designated credit unions(LICU); LICU information collection burdens; Loan Level Price adjustments and Guaranty Fees; HR5541, Financial Services for the Underserved Act of 2016; NCUAs proposed rule regarding FCU occupancy, planning, and disposal of acquired and abandoned premises; HR 1486, Taking Account of Bureaucrats Spending Act (TABS); HR 4773, the Protection Workplace Advancement and Opportunity Act; HR 4538, the Senior$afe Act; NCUAs proposed rule on Incentive-Based Compensation Arrangement; NCUAs Exam Flexibility Initiative; issues related to the National Credit Union Share Insurance Funds Equity Ratio; NCUAs Regulatory Review; seeking guidance from NCUA on interpretation of overall financial performance; NCUAs Revised Examiner Guidance; NCUA to revise CUSO reporting requirements; CUSO accounting standards, Amend NCUA thresholds for supervisory committee audits and verifications; NCUA to address duplicative nature of Fair Credit Reporting regulations; Incidental Powers; requirements for share insurance; Update call reports; DOJs ANPR on accessibility of web information and services of State and Local Government entities; CFPBs amendment to Regulation Ps Annual Privacy Notice Requirement; NCUAs modernization of data collection for regulatory oversight of credit unions; CFPBs proposed rule on arbitration agreements; Property Assessed Clean Energy (PACE) Loans; NCUAs proposed amendments to the Community Development Revolving Loan Fund; modernization of Federal Credit union Bylaws; FHFAs development of a Common Securitization Platform; NIST request for comment on current and future states of cybersecurity in the digital economy; DOD to give better guidance and extend effective date on Military Lending Act Rule; comments on CFPBs Outline of Proposals Under Consideration and Alternatives Considered regarding Third-Party debt collection practices; comments on Consumer Response Company Response Survey; H.R. 5983, the Financial CHOICE Act; H.R. 4038, the Community Financial Institution Exemption Act; H.R. 6094, Regulatory Relief for Small Businesses, Schools, and Non-Profits Act; CFPBs proposed rule related to Payday, Vehicle Title and Certain High-Cost Installment Loans; Single-Family Credit Risk Transfer and proposals to adopt additional front-end credit risk transfer structures; rebates to credit unions related to the Temporary Corporate Credit Union Stabilization Fund; CFPB request for comment on Amendments Relating to Disclosure of Records and Information; NCUAs 2017 and 2018 proposed budgets; NCUAs Equity Fund Ratio and 2017 Projections; Changes to NCUAs Chartering and Field of Membership Manual.
Client expense: $640,000 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office
2016 · fourth_quarter · Financial Institutions/Investments/Securities
Consumer Financial Protection Bureaus (CFPB) Notice and Request for Comment on Web-Based Quantitative Testing Point of Sale/ATM (POS/ATM) Overdraft Disclosure Forms; Comments responding to request for information on the FHFAs proposed collection of information relating to the NSEMB; Comments on Regulatory Impact Assessment and Initial Regulatory Flexibility Analysis, RIN 1506-AB25; Concerns with CFPB future payday lending rulemakings; payday lending as related to the CFPB Proposals; H.R. 3192: Homebuyers Assistance Act; H.R. 2769: Risk-Based Capital Study Act; National Credit Union Administrations (NCUA) risk-based capital proposal; H.R. 2205: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; NCUAs budget; H.R. 1176: NCUA Budget Transparency Act/ GAO Study of NCUA budgeting practices; H.R. 1188: Credit Union Small Business Jobs Creation Act/ raising MBL cap; H.R. 1195: Bureau of Consumer Financial Protection Advisory Boards Act; H.R. 1210: Portfolio Lending and Mortgage Access Act; H.R. 2473: Preserving Capital Access and Mortgage Liquidity Act of 2015; H.R. 2896: the TAILOR Act of 2015; S. 754: Cyber Security Information Sharing Act; NAFCUs Five Point Plan for Regulatory Relief (capital reforms for credit unions; field of membership improvements for credit unions; reduced consumer financial protection bureaus on credit unions; operational improvements for credit unions; 21st century data security standards); Regulatory relief for credit unions; Impact of Federal Regulations on Credit Unions; S. 961: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; NCUAs efforts to allow credit unions to better serve rural areas; H.R. 1259: Helping Expand Lending Practices in Rural Communities Act; CFPBs interim final rule amending Regulation Z; H.R. 1261: Bureau of Consumer Financial Protection Accountability Act/ Subjects CFPB to Congressional appropriations process; S. 774: Financial Institutions Examination Fairness and Reform Act; S. 871: HELP Rural Communities Act of 2015/ CFPB Rural Definition; H.R. 685: Mortgage Choice Act of 2015/ Points and Fees; H.R. 1408: Mortgage Servicing Asset Capital Requirements Act; H.R. 1422: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; H.R. 1529: Community Institution Mortgage Relief Act of 2015; H.R. 1941: Financial Institutions Examination Fairness and Reform Act; Regulatory Burdens; Qualified Mortgage Rule; S. 1484: Financial Regulatory Improvement Act; Federal Credit Union Act; S. 2028: A bill to amend the Federal Credit Union Act, to advance the ability of credit unions to promote small business growth and economic development opportunities, and for other purposes; H.R. 3738: the Office of Financial Research Accountability Act of 2015; H.R. 3557: the FSOC Transparency and Accountability Act; H.R. 1660: the Federal Savings Association Charter Flexibility Act; Improve the federal charter of credit unions through the FCU Act; H.R. 989: Capital Access for Small Businesses and Jobs Act/ Supplemental Capital; H.R. 1133: To exclude extensions of credit made to veterans from the definition of a member business loan under the Federal Credit Union Act; NCUA proposed rulemaking on a federal insured credit unions member business lending; NCUAs exam scheduling policy; NAFCUs Top Ten Regulations for Eliminate of Amend (improve process for credit unions seeking changes to their field of membership; provide more meaningful exemptions for small institutions; Dodd-Frank 1022 Authority; expand credit union investment authority; allowing more transfers per month from savings accounts per Federal Reserve Regulation D; flexibility for credit unions making member business loans; NCUAs member business lending rule: update requirement to disclose account numbers to protect privacy of members; update advertising requirements for loan products and share accounts; Accuracy of advertising and notice of insured status; seek improvements to the NCUA Central Liquidity Facility (CLF); CLF information collection; CLF modernization to obtain flexibility for federal credit unions to determine their choice of law; update simplify and make improvements to regulations governing check processing funds); S. 423: Privacy Notice Modernization Act of 2015; H.R. 22: the Surface Transportation Reauthorization and Reform Act of 2015; NCUAs proposed Field of Membership Amendments; H.R. 2995: Financial Services and General Government Appropriations Act; Require the CFPB to conduct a fair, comprehensive study before adopting a rule that would restrict arbitration and open the door to abusive class actions; prevent arbitration restrictions; NCUA third party vendor authority; CFPB request for approval under the Paperwork Reduction Act to conduct a national web-based survey relative to overdraft protection services; CFPB consumer complaint narrative database; CFPB and the student loan servicing market; Student Loan Borrower Communication ;CFPB integration of the Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) disclosures, consider good faith efforts to comply with TRID; financial regulators must level the playing field and promulgate rules that require non-traditional market lenders to meet basic consumer protection requirements such as those of TILA, underwriting standards for loans, and applicable state usury laws; NCUAs usury ceiling under the FCU Act; FSOC should facilitate regulatory coordination among its member regulators; preserve the credit union tax exemption; regulatory relief including CFPB using their exemption authority more; Housing Finance Reform - it is vital that credit unions continue to have unfettered access to the secondary mortgage market and any reforms should have emphasis on fair pricing that reflects loan quality rather than quantity; Department of Labors proposed changes to the Fair Labor Standards Act for certain full-time salaried works to be eligible for overtime protections; Federal Communication Commission clarification for free end user calls made by financial institutions; Federal Communication Commission regarding clarifications to the interpretations of the Telephone Consumer Protection Act; FCCs Declaratory Ruling and Order on TCPA; H.R. 1155: the Searching for and Cutting Regulations that are unnecessarily Burdensome (SCRUB) Act; prepaid cards - CFPB efforts to ensure that consumers using prepaid products are sufficiently informed and protected - they should find appropriate balance between adequate consumer protection and allowing consumers access to products they demand; compliance burdens related to CFPB amendments to Regulation C, HMDA; Uniform Residential Loan Application (URLA); Periodic Statements for Borrowers who have filed for bankruptcy; Statement production systems and CFPBs servicing regulations; Small Business Administration SBA 7(a) business loan program; H.R. 2499: Veterans Entrepreneurship Act of 2015; FY 2016 Financial Services and General Government Appropriations bill; H.R. 427: Regulations for the Executive in Need of Scrutiny Act of 2015; Improve agency use of regulatory guidance; Protect responsible overdraft services; Changes to requirements under the Home Mortgage Disclosure Act; H.R. 957: Bureau of Consumer Financial Protection Inspector General Reform Act; Reform of Fannie Mae and Freddie Mac; Credit risk-guarantee fees; Military Lending Act; H.R. 1735: National Defense Authorization Act for Fiscal Year 2016; Cost-benefit analysis at federal regulatory agencies; Regulatory coordination; Regulations related to remittance transfers; Legal opinion letters at the CFPB and NCUA; H.R. 9: Innovation Act; H.R. 185: Regulatory Accountability Act of 2015; H.R. 527: Small Business Regulatory Flexibility Improvements Act of 2015; H.R. 650: Preserving Access to Manufactured Housing Act; H.R. 766: Financial Institution Customer Protection Act/ Ending Operation Choke Point; H.R. 1262: Consumer Right to Financial Privacy Act of 2015; H.R. 1263: Consumer Financial Protection Safety and Soundness Improvement Act/ Changes veto authority of the Financial Stability Oversight Council; H.R. 1265: Bureau Advisory Commission Transparency Act/ Making credit union advisory council meetings public; H.R. 1266: Financial Product Safety Commission Act/ Replacing CFPB Director with Commission; H.R. 1309: Systemic Risk Designation Improvement Act of 2015; S. 881: Comprehensive Regulatory Review Act of 2015; S. 924: To require public hearings on NCUA's budget; S. 1137: PATENT Act; S. 1440: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; Ensure an Effective Payments system; Fairness under FCC ruling on autodialing and FCC oversight; Telephone Consumer Protection Act; modernize online lending laws and regulations; give NCUA greater flexibility with credit union lending including the ability to establish longer maturities for certain loans; preventing g-fees charged by Fannie and Freddie from being used as funding offset; NCUA 18-month Exam Cycle; Military Lending Act Database; Credit Losses Accounting Standard; FASB Accounting Standards; CFPBs expansion of data collection under Reg C, Privacy protections for data collected by CFPB; NIST notice and request for information on views on the Framework for Improving Critical Infrastructure Cybersecurity; Comments on Notice of proposed rulemaking regarding field of membership and chartering; CBSA population limit, combined statistical area, well defined local communities, rural population limits, multiple common bond charters, underserved areas, TIP charters; CFPB information collection on compliance costs and other effects of regulation; Duty to serve underserved markets; interchange rates as related to the Durbin Amendment to Dodd-Frank; Repeal Durbin Amendment; H.R. 5465 - to repeal Durbin Amendment; Federal Reserves EGRPRA review process; FHFAs principal reduction consideration; FFIEC Cybersecurity Assessment Tool; FFIEC proposed revision to the Uniform Interagency Consumer Compliance Rating System; Department of Labor Fiduciary Rule, Department of Labor overtime Rule; Administrative Procedures Act; Regulatory Flexibility for credit unions; Promote Consumer Protection and Financial Literacy; Financial Technology (FinTech); FinTech and online marketplace lending; Transparency for NCUAs Overhead Transfer Rate methodology; Transparency for NCUAs Operating Fee methodology; FY 2017 Financial Services and General Government Appropriations Bill; Community Development Financial Institution funding (CDFI); CDFI certification and reporting requirements; Dept. of Treasurys National Strategy for financial literacy and education; NCUAs information collection on investment and deposit activities; allow credit unions to purchase loans from other originators for purposes of issuing securities; mortgage servicing rights; extend exemption for consumer credit cards from MLA Rule requirements; Secondary Capital for low-income designated credit unions(LICU); LICU information collection burdens; Loan Level Price adjustments and Guaranty Fees; HR5541, Financial Services for the Underserved Act of 2016; NCUAs proposed rule regarding FCU occupancy, planning, and disposal of acquired and abandoned premises; HR 1486, Taking Account of Bureaucrats Spending Act (TABS); HR 4773, the Protection Workplace Advancement and Opportunity Act; HR 4538, the Senior$afe Act; NCUAs proposed rule on Incentive-Based Compensation Arrangement; NCUAs Exam Flexibility Initiative; issues related to the National Credit Union Share Insurance Funds Equity Ratio; NCUAs Regulatory Review; seeking guidance from NCUA on interpretation of overall financial performance; NCUAs Revised Examiner Guidance; NCUA to revise CUSO reporting requirements; CUSO accounting standards, Amend NCUA thresholds for supervisory committee audits and verifications; NCUA to address duplicative nature of Fair Credit Reporting regulations; Incidental Powers; requirements for share insurance; Update call reports; DOJs ANPR on accessibility of web information and services of State and Local Government entities; CFPBs amendment to Regulation Ps Annual Privacy Notice Requirement; NCUAs modernization of data collection for regulatory oversight of credit unions; CFPBs proposed rule on arbitration agreements; Property Assessed Clean Energy (PACE) Loans; NCUAs proposed amendments to the Community Development Revolving Loan Fund; modernization of Federal Credit union Bylaws; FHFAs development of a Common Securitization Platform; NIST request for comment on current and future states of cybersecurity in the digital economy; DOD to give better guidance and extend effective date on Military Lending Act Rule; comments on CFPBs Outline of Proposals Under Consideration and Alternatives Considered regarding Third-Party debt collection practices; comments on Consumer Response Company Response Survey; H.R. 5983, the Financial CHOICE Act; H.R. 4038, the Community Financial Institution Exemption Act; H.R. 6094, Regulatory Relief for Small Businesses, Schools, and Non-Profits Act; CFPBs proposed rule related to Payday, Vehicle Title and Certain High-Cost Installment Loans; Single-Family Credit Risk Transfer and proposals to adopt additional front-end credit risk transfer structures; rebates to credit unions related to the Temporary Corporate Credit Union Stabilization Fund; CFPB request for comment on Amendments Relating to Disclosure of Records and Information; NCUAs 2017 and 2018 proposed budgets; NCUAs Equity Fund Ratio and 2017 Projections; Changes to NCUAs Chartering and Field of Membership Manual.
Client expense: $640,000 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office
2016 · fourth_quarter · Banking
Issues related to credit union operations Issues related to credit union field of membership Issues related to credit union service organizations Issues related to vacancies on the National Credit Union Administration (NCUA) Board Issues related to NCUAs low income designation regulations Issues related to NCUA examination procedures Issues related to NCUAs regulation regarding its regulatory flexibility program Issues related to NCUAs proposed rule regarding emergency liquidity Issues related to NCUAs rulemaking process Issues related to material loss reports of the NCUA Office of Inspector General Issues related to the authority of the CFPB to exempt credit unions from its rulemaking Issues related to the CFPB proposal related to remittances and international wire transfers Issues related to the proposed CFPB form on RESPA/TILA Issues related to CFPBs Leadership Structure and Installing a Board Rather than Director Issues related to funding the CFPB through the Appropriations Process Issues related to increasing the CFPB Examination Threshold Issues related to conducting a cost-benefit analysis of all CFPB Proposals Issues related to codifying the CFPBs Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to standardizing the definition of mortgage originator Issues related to overdraft protection and check ordering practices Issues related to mortgage servicing Issues related to mortgage loan originator compensation and qualifications Issues related to high-cost mortgage loans (HOEPA) Issues related to the CFPBs proposed rule regarding qualified mortgage / ability to repay Issues related to reverse mortgages Issues related to the Financial Accounting Standards Board (FASB) Issues related to mark-to-market accounting Issues related to private equity standards Issues related to the implementation of the Unlawful Internet Gambling Prohibition Act Issues related to data and cyber security Issues related to mobile banking and mobile payments Issues related to the oversight of the Federal Housing Administration Issues related to USDA Rural Development Loan program Issues related to identity theft and fraud reduction Issues related to student lending Issues related to the Federal Home Loan Bank System Issues related to short term lending products and advance deposit products Issues related to patent reform Issues related to Federal Credit Union bylaws Issues relating to home-based credit unions Issues related to NCUAs risk-based capital proposal Issues related to NCUAs proposed rule on securitization Issues related to NCUAs regulatory review process Issues related to credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union by-laws Issues related to credit unions incidental powers Issues related to credit unions ability to offer prepaid cards Issues related to Ginnie Mae capital Issues related to credit union service to marijuana businesses Issues related to financial literacy Issues related to the Department of Justices investigation entitled, Operation Choke Point Issues related to membership eligibility in the Federal Home Loan Bank System. Issues related to the Department of Defense proposal regarding Credit Extending to Service Members under MLA Issues related to the Economic Growth and Regulatory Paperwork Reduction Act process Issues related to indirect auto lending Issues related to fixed assets Issues related to merchant data breaches Issues related to the payments system Issues related to FHFA proposed rules and FHLB eligibility for credit unions Issues related to Federal Reserve Regulatory D Issues related to 1-4 Family Non-Owner Occupied Residential Loan Treatment as Residential Rather than Business Loans Issues related to the use of Eminent Domain to Seize Performing Mortgage Loans Issues related to Housing Finance Reform Issues related to the implementation of the remittances provisions in the Dodd-Frank Act Issues related to NCUAs proposal rule on Member Business Lending Issues related to NCUAs proposed rule on Interest on Lawyer Trust Accounts (IOLTA) Issues related to credit union service to unbanked and underbanked consumers Issues related to the United States Postal Service Office of Inspector General report related to role of the postal service in financial services Issues related to the Feds implementation of same-day ACH Issues related to the regulation of corporate credit unions Issues related to the CFPBs proposed regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the payday, vehicle title, and similar lending Issues related to the CFPBs consumer complaint database Issues related to NCUAs Fixed Assets rule Issues related to NCUAs definition of small entity Issues related to NCUA's Proposed Rule on Member Business Lending Issues related to the Department of Labor's Proposed Rule on the Definition of Fiduciary Issues related to the Telephone Consumer Protection Act Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements Issues related to the Department of Labor's Proposed Overtime Eligibility rule Issues related to credit union conversions Issues related to the CFPB's proposal on arbitration Issues related to secure payments Issues related to credit union call report modernization H.R. 9, the Innovation Act, all provisions H.R. 22, the FAST Act, Title LXXV, provisions related to privacy notice requirements; Title LXXXII, provisions related to the eligibility of privately insured credit unions to join a Federal Home Loan Bank; Title LXXXIX, provisions related to the designation of rural areas by the Consumer Financial Protection Bureau H.R. 185, Regulatory Accountability Act of 2015 H.R. 299, the Capital Access for Small Community Financial Institutions Act of 2015, all provisions H.R. 527, the Small Business Regulatory Flexibility Improvements Act of 2015 H.R. 601, the Eliminate Privacy Notice Confusion Act, all provisions H.R. 650, Preserving Access to Manufactured Housing Act, all provision H.R. 685, the Mortgage Choice Act, all provisions H.R. 766, Financial Institution Consumer Protection Act, all provisions H.R. 957, the Bureau of Consumer Financial Protection Inspector General Reform Act, all provisions H.R. 989, the Capital Access for Small Businesses Jobs Creation Act, all provisions H.R. 1090, Retail Investor Protection Act, all provisions H.R. 1176, the NCUA Budget Transparency Act, all provisions H.R. 1188, the Credit Union Small Business Jobs Creation Act, all provisions H.R. 1195, the Bureau of Consumer Financial Protection Advisory Boards Act, all provisions H.R. 1210, the Portfolio Lending and Mortgage Access Act, H.R. 1233, the Community Lending Enhancement and Regulatory Relief Act of 2015 H.R. 1259, the Helping Expand Lending Practices in Rural Communities Act, all provisions H.R. 1263, Consumer Financial Protection Safety and Soundness Improvement Act of 2015 H.R. 1265, the Bureau Advisory Commission Transparency Act, all provision H.R. 1266, the Financial Products Safety Commission Act of 2015 H.R. 1408, requiring a study of the capital requirements for mortgage servicing assets H.R. 1422, the Credit Union Residential Loan Parity Act H.R. 1480, the SAFE Confidentiality and Privilege Enhancement Act H.R. 1523, Community Bank Access to Capital Act of 2015 H.R. 1529, the Community Institution Mortgage Relief Act Discussion Draft, Data Security and Breach Notification Act of 2015 H.R. 1660, the Federal Savings Association Charter Flexibility Act, all provisions H.R. 1941, the Financial Institution Examination Fairness and Reform Act H.R. 2205, the Data Security Act H.R. 2213, to provide for a temporary safe harbor from the enforcement of integrated disclosure requirements for mortgage loan transactions under the Real Estate Settlement Procedures Act of 1974 and the Truth in Lending Act, and for other purposes. H.R. 2287, the National Credit Union Administration Budget Transparency Act H.R. 2473, the Preserving Capital Access and Mortgage Liquidity Act H.R. 2769, the Risk-Based Capital Study Act, all provisions H.R. 2896, the Taking Account of Institutions with Low Operation Risk (TAILOR) Act H.R. 3192, the Homebuyer Assistance Act, all provisions H.R. 4538, the Senior $afe Act, all provisions H.R. 4893, the Risk Management and Homeowner Stability Act, all provisions H.R. 4997, the Home Mortgage Disclosure Adjustment Act, all provisions H.R. 5465, a bill to repeal section 1075 of the Consumer Financial Protection Act of 2010 relating to rules for payment card transactions, all provisions H.R. 5983, the Financial CHOICE Act, all provisions S. 423, the Privacy Notice Modernization Act, all provisions S. 482, the Consumer Financial Protection Bureau Examination Reporting Threshold Act of 2015, all provisions S. 774 Financial Institutions Examination Fairness and Reform Act, all provisions S. 871, the Helping Expand Lending Practices in (HELP) Rural Communities Act S. 924, the National Credit Union Administration Budget Transparency Act S. 961, the Data Security Act S. 1367, a bill to amend the Federal Home Loan Bank Act with respect to membership eligibility of certain institutions S. 1440, the Credit Union Residential Loan Parity Act S. 1484, the Financial Regulatory Improvement Act, Title I S. 2216, the Senior$afe Act, all provisions The Heck-Stivers Amendment to H.R. 1735, the National Defense Authorization Act, related to the Department of Defenses MLA Database Discussion draft of the Financial Creating Hope and Opportunity for Investors, Consumers and Entrepreneurs (CHOICE) Act, all provisions
Client expense: $920,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Consumer Financial Protection Bureau (CFPB), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), SENATE, Small Business Administration (SBA), Treasury, Dept of
2016 · fourth_quarter · Banking
H.R. 989, supplemental capital. H.R. 1188 member business lending. H.R. 1133 veterans exemption to member business lending cap. H.R. 299 privately insured credit unions. H.R. 601 privacy notifications.H.R. 1422 residential parity. H.R. 2679, risk based capital stop and study act. S. 1484, regulatory relief. S.2028, member business lending. S. 1440, residential parity. S. 961, data security. Merchant data breaches as they apply to financial institutions. EMV chip-card conversions. National Credit Union Administration and Consumer Financial Protection Bureau regulatory issues. Proposed rules on Field of Membership and Member Business Lending. Credit union examinations. Risk-based capital. Truth in lending disclosures (TRID). HMDA Home Mortgage Disclosure Act. Community lender exemption authority to Dodd-Frank Wall Street Reform and Consumer Protection Act. Property Assessed Clean Energy (PACE) lending and priority liens. Fair Credit Reporting Act - Federal Trade Commission. Cannabis banking.
Client expense: $110,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), SENATE
2016 · third_quarter · Financial Institutions/Investments/Securities
Consumer Financial Protection Bureaus (CFPB) Notice and Request for Comment on Web-Based Quantitative Testing Point of Sale/ATM (POS/ATM) Overdraft Disclosure Forms; Comments responding to request for information on the FHFAs proposed collection of information relating to the NSEMB; Comments on Regulatory Impact Assessment and Initial Regulatory Flexibility Analysis, RIN 1506-AB25; Concerns with CFPB future payday lending rulemakings; payday lending as related to the CFPB Proposals; H.R. 3192: Homebuyers Assistance Act; H.R. 2769: Risk-Based Capital Study Act; National Credit Union Administrations (NCUA) risk-based capital proposal; H.R. 2205: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; NCUAs budget; H.R. 1176: NCUA Budget Transparency Act/ GAO Study of NCUA budgeting practices; H.R. 1188: Credit Union Small Business Jobs Creation Act/ raising MBL cap; H.R. 1195: Bureau of Consumer Financial Protection Advisory Boards Act; H.R. 1210: Portfolio Lending and Mortgage Access Act; H.R. 2473: Preserving Capital Access and Mortgage Liquidity Act of 2015; H.R. 2896: the TAILOR Act of 2015; S. 754: Cyber Security Information Sharing Act; NAFCUs Five Point Plan for Regulatory Relief (capital reforms for credit unions; field of membership improvements for credit unions; reduced consumer financial protection bureaus on credit unions; operational improvements for credit unions; 21st century data security standards); Regulatory relief for credit unions; Impact of Federal Regulations on Credit Unions; S. 961: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; NCUAs efforts to allow credit unions to better serve rural areas; H.R. 1259: Helping Expand Lending Practices in Rural Communities Act; CFPBs inerim final rule amending Regulation Z; H.R. 1261: Bureau of Consumer Financial Protection Accountability Act/ Subjects CFPB to Congressional appropriations process; S. 774: Financial Institutions Examination Fairness and Reform Act; S. 871: HELP Rural Communities Act of 2015/ CFPB Rural Definition; H.R. 685: Mortgage Choice Act of 2015/ Points and Fees; H.R. 1408: Mortgage Servicing Asset Capital Requirements Act; H.R. 1422: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; H.R. 1529: Community Institution Mortgage Relief Act of 2015; H.R. 1941: Financial Institutions Examination Fairness and Reform Act; Regulatory Burdens; Qualified Mortgage Rule; S. 1484: Financial Regulatory Improvement Act; Federal Credit Union Act; S. 2028: A bill to amend the Federal Credit Union Act, to advance the ability of credit unions to promote small business growth and economic development opportunities, and for other purposes; H.R. 3738: the Office of Financial Research Accountability Act of 2015; H.R. 3557: the FSOC Transparency and Accountability Act; H.R. 1660: the Federal Savings Association Charter Flexibility Act; Improve the federal charter of credit unions through the FCU Act; H.R. 989: Capital Access for Small Businesses and Jobs Act/ Supplemental Capital; H.R. 1133: To exclude extensions of credit made to veterans from the definition of a member business loan under the Federal Credit Union Act; NCUA proposed rulemaking on a federal insured credit unions member business lending; NCUAs exam scheduling policy; NAFCUs Top Ten Regulations for Eliminate of Amend (improve process for credit unions seeking changes to their field of membership; provide more meaningful exemptions for small institutions; Dodd-Frank 1022 Authority; expand credit union investment authority; allowing more transfers per month from savings accounts per Federal Reserve Regulation D; flexibility for credit unions making member business loans; NCUAs member business lending rule: update requirement to disclose account numbers to protect privacy of members; update advertising requirements for loan products and share accounts; Accuracy of advertising and notice of insured status; seek improvements to the NCUA Central Liquidity Facility (CLF); CLF information collection; CLF modernization to obtain flexibility for federal credit unions to determine their choice of law; update simplify and make improvements to regulations governing check processing funds); S. 423: Privacy Notice Modernization Act of 2015; H.R. 22: the Surface Transportation Reauthorization and Reform Act of 2015; NCUAs proposed Field of Membership Amendments; H.R. 2995: Financial Services and General Government Appropriations Act; Require the CFPB to conduct a fair, comprehensive study before adopting a rule that would restrict arbitration and open the door to abusive class actions; prevent arbitration restrictions; NCUA third party vendor authority; CFPB request for approval under the Paperwork Reduction Act to conduct a national web-based survey relative to overdraft protection services; CFPB consumer complaint narrative database; CFPB and the student loan servicing market; Student Loan Borrower Communication ;CFPB integration of the Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) disclosures, consider good faith efforts to comply with TRID; financial regulators must level the playing field and promulgate rules that require non-traditional market lenders to meet basic consumer protection requirements such as those of TILA, underwriting standards for loans, and applicable state usury laws; FSOC should facilitate regulatory coordination among its member regulators; preserve the credit union tax exemption; regulatory relief including CFPB using their exemption authority more; Housing Finance Reform - it is vital that credit unions continue to have unfettered access to the secondary mortgage market and any reforms should have emphasis on fair pricing that reflects loan quality rather than quantity; Department of Labors proposed changes to the Fair Labor Standards Act for certain full-time salaried works to be eligible for overtime protections; Federal Communication Commission clarification for free end user calls made by financial institutions; Federal Communication Commission clarification regarding clarifications to the interpretations of the Telephone Consumer Protection Act; FCCs Declaratory Ruling and Order on TCPA; H.R. 1155: the Searching for and Cutting Regulations that are unnecessarily Burdensome (SCRUB) Act; prepaid cards - CFPB efforts to ensure that consumers using prepaid products are sufficiently informed and protected - they should find appropriate balance between adequate consumer protection and allowing consumers access to products they demand; compliance burdens related to CFPB amendments to Regulation C, HMDA; Uniform Residential Loan Application (URLA); Periodic Statements for Borrowers who have filed for bankruptcy; Statement production systems and CFPBs servicing regulations; Small Business Administration SBA 7(a) business loan program; H.R. 2499: Veterans Entrepreneurship Act of 2015; FY 2016 Financial Services and General Government Appropriations bill; H.R. 427: Regulations for the Executive in Need of Scrutiny Act of 2015; Improve agency use of regulatory guidance; Protect responsible overdraft services; Changes to requirements under the Home Mortgage Disclosure Act; H.R. 957: Bureau of Consumer Financial Protection Inspector General Reform Act; Reform of Fannie Mae and Freddie Mac; Credit risk-guarantee fees; Military Lending Act; H.R. 1735: National Defense Authorization Act for Fiscal Year 2016; Cost-benefit analysis at federal regulatory agencies; Regulatory coordination; Regulations related to remittance transfers; Legal opinion letters at the CFPB and NCUA; H.R. 9: Innovation Act; H.R. 185: Regulatory Accountability Act of 2015; H.R. 527: Small Business Regulatory Flexibility Improvements Act of 2015; H.R. 650: Preserving Access to Manufactured Housing Act; H.R. 766: Financial Institution Customer Protection Act/ Ending Operation Choke Point; H.R. 1262: Consumer Right to Financial Privacy Act of 2015; H.R. 1263: Consumer Financial Protection Safety and Soundness Improvement Act/ Changes veto authority of the Financial Stability Oversight Council; H.R. 1265: Bureau Advisory Commission Transparency Act/ Making credit union advisory council meetings public; H.R. 1266: Financial Product Safety Commission Act/ Replacing CFPB Director with Commission; H.R. 1309: Systemic Risk Designation Improvement Act of 2015; S. 881: Comprehensive Regulatory Review Act of 2015; S. 924: To require public hearings on NCUA's budget; S. 1137: PATENT Act; S. 1440: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; Ensure an Effective Payments system; Fairness under FCC ruling on autodialing and FCC oversight; Telephone Consumer Protection Act; modernize online lending laws and regulations; give NCUA greater flexibility with credit union lending including the ability to establish longer maturities for certain loans; preventing g-fees charged by Fannie and Freddie from being used as funding offset; NCUA 18-month Exam Cycle; Military Lending Act Database; Credit Losses Accounting Standard; FASB Accounting Standards; CFPBs expansion of data collection under Reg C, Privacy protections for data collected by CFPB; NIST notice and request for information on views on the Framework for Improving Critical Infrastructure Cybersecurity; Comments on Notice of proposed rulemaking regarding field of membership and chartering; CBSA population limit, combined statistical area, well defined local communities, rural population limits, multiple common bond charters, underserved areas, TIP charters; CFPB information collection on compliance costs and other effects of regulation; Duty to serve underserved markets; interchange rates as related to the Durbin Amendment to Dodd-Frank; Repeal Durbin Amendment; H.R. 5465 - to repeal Durbin Amendment; Federal Reserves EGRPRA review process; FHFAs principal reduction consideration; FFIEC Cybersecurity Assessment Tool; FFIEC proposed revision to the Uniform Interagency Consumer Compliance Rating System; Department of Labor Fiduciary Rule, Department of Labor overtime Rule; Administrative Procedures Act; Regulatory Flexibility for credit unions; Promote Consumer Protection and Financial Literacy; Financial Technology (FinTech); FinTech and online marketplace lending; Transparency for NCUAs Overhead Transfer Rate methodology; Transparency for NCUAs Operating Fee methodology; FY 2017 Financial Services and General Government Appropriations Bill; Community Development Financial Institution funding (CDFI); CDFI certification and reporting requirements; Dept. of Treasurys National Strategy for financial literacy and education; NCUAs information collection on investment and deposit activities; allow credit unions to purchase loans from other originators for purposes of issuing securities; mortgage servicing rights; extend exemption for consumer credit cards from MLA Rule requirements; Secondary Capital for low-income designated credit unions(LICU); LICU information collection burdens; Loan Level Price adjustments and Guaranty Fees; HR5541, Financial Services for the Underserved Act of 2016; NCUAs proposed rule regarding FCU occupancy, planning, and disposal of acquired and abandoned premises; HR 1486, Taking Account of Bureaucrats Spending Act (TABS); HR 4773, the Protection Workplace Advancement and Opportunity Act; HR 4538, the Senior$afe Act; NCUAs proposed rule on Incentive-Based Compensation Arrangement; NCUAs Exam Flexibility Initiative; issues related to the National Credit Union Share Insurance Funds Equity Ratio; NCUAs Regulatory Review; seeking guidance from NCUA on interpretation of overall financial performance; NCUAs Revised Examiner Guidance; NCUA to revise CUSO reporting requirements; CUSO accounting standards, Amend NCUA thresholds for supervisory committee audits and verifications; NCUA to address duplicative nature of Fair Credit Reporting regulations; Incidental Powers; requirements for share insurance; Update call reports; DOJs ANPR on accessibility of web information and services of State and Local Government entities; CFPBs amendment to Regulation Ps Annual Privacy Notice Requirement; NCUAs modernization of data collection for regulatory oversight of credit unions; CFPBs proposed rule on arbitration agreements; Property Assessed Clean Energy (PACE) Loans; NCUAs proposed amendments to the Community Development Revolving Loan Fund; modernization of Federal Credit union Bylaws; FHFAs development of a Common Securitization Platform; NIST request for comment on current and future states of cybersecurity in the digital economy; DOD to give better guidance and extend effective date on Military Lending Act Rule; comments on CFPBs Outline of Proposals Under Consideration and Alternatives Considered regarding Third-Party debt collection practices; comments on Consumer Response Company Response Survey; H.R. 5983, the Financial CHOICE Act; H.R. 4038, the Community Financial Institution Exemption Act; H.R. 6094, Regulatory Relief for Small Businesses, Schools, and Non-Profits Act.
2016 · third_quarter · Banking
Consumer Financial Protection Bureaus (CFPB) Notice and Request for Comment on Web-Based Quantitative Testing Point of Sale/ATM (POS/ATM) Overdraft Disclosure Forms; Comments responding to request for information on the FHFAs proposed collection of information relating to the NSEMB; Comments on Regulatory Impact Assessment and Initial Regulatory Flexibility Analysis, RIN 1506-AB25; Concerns with CFPB future payday lending rulemakings; payday lending as related to the CFPB Proposals; H.R. 3192: Homebuyers Assistance Act; H.R. 2769: Risk-Based Capital Study Act; National Credit Union Administrations (NCUA) risk-based capital proposal; H.R. 2205: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; NCUAs budget; H.R. 1176: NCUA Budget Transparency Act/ GAO Study of NCUA budgeting practices; H.R. 1188: Credit Union Small Business Jobs Creation Act/ raising MBL cap; H.R. 1195: Bureau of Consumer Financial Protection Advisory Boards Act; H.R. 1210: Portfolio Lending and Mortgage Access Act; H.R. 2473: Preserving Capital Access and Mortgage Liquidity Act of 2015; H.R. 2896: the TAILOR Act of 2015; S. 754: Cyber Security Information Sharing Act; NAFCUs Five Point Plan for Regulatory Relief (capital reforms for credit unions; field of membership improvements for credit unions; reduced consumer financial protection bureaus on credit unions; operational improvements for credit unions; 21st century data security standards); Regulatory relief for credit unions; Impact of Federal Regulations on Credit Unions; S. 961: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; NCUAs efforts to allow credit unions to better serve rural areas; H.R. 1259: Helping Expand Lending Practices in Rural Communities Act; CFPBs inerim final rule amending Regulation Z; H.R. 1261: Bureau of Consumer Financial Protection Accountability Act/ Subjects CFPB to Congressional appropriations process; S. 774: Financial Institutions Examination Fairness and Reform Act; S. 871: HELP Rural Communities Act of 2015/ CFPB Rural Definition; H.R. 685: Mortgage Choice Act of 2015/ Points and Fees; H.R. 1408: Mortgage Servicing Asset Capital Requirements Act; H.R. 1422: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; H.R. 1529: Community Institution Mortgage Relief Act of 2015; H.R. 1941: Financial Institutions Examination Fairness and Reform Act; Regulatory Burdens; Qualified Mortgage Rule; S. 1484: Financial Regulatory Improvement Act; Federal Credit Union Act; S. 2028: A bill to amend the Federal Credit Union Act, to advance the ability of credit unions to promote small business growth and economic development opportunities, and for other purposes; H.R. 3738: the Office of Financial Research Accountability Act of 2015; H.R. 3557: the FSOC Transparency and Accountability Act; H.R. 1660: the Federal Savings Association Charter Flexibility Act; Improve the federal charter of credit unions through the FCU Act; H.R. 989: Capital Access for Small Businesses and Jobs Act/ Supplemental Capital; H.R. 1133: To exclude extensions of credit made to veterans from the definition of a member business loan under the Federal Credit Union Act; NCUA proposed rulemaking on a federal insured credit unions member business lending; NCUAs exam scheduling policy; NAFCUs Top Ten Regulations for Eliminate of Amend (improve process for credit unions seeking changes to their field of membership; provide more meaningful exemptions for small institutions; Dodd-Frank 1022 Authority; expand credit union investment authority; allowing more transfers per month from savings accounts per Federal Reserve Regulation D; flexibility for credit unions making member business loans; NCUAs member business lending rule: update requirement to disclose account numbers to protect privacy of members; update advertising requirements for loan products and share accounts; Accuracy of advertising and notice of insured status; seek improvements to the NCUA Central Liquidity Facility (CLF); CLF information collection; CLF modernization to obtain flexibility for federal credit unions to determine their choice of law; update simplify and make improvements to regulations governing check processing funds); S. 423: Privacy Notice Modernization Act of 2015; H.R. 22: the Surface Transportation Reauthorization and Reform Act of 2015; NCUAs proposed Field of Membership Amendments; H.R. 2995: Financial Services and General Government Appropriations Act; Require the CFPB to conduct a fair, comprehensive study before adopting a rule that would restrict arbitration and open the door to abusive class actions; prevent arbitration restrictions; NCUA third party vendor authority; CFPB request for approval under the Paperwork Reduction Act to conduct a national web-based survey relative to overdraft protection services; CFPB consumer complaint narrative database; CFPB and the student loan servicing market; Student Loan Borrower Communication ;CFPB integration of the Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) disclosures, consider good faith efforts to comply with TRID; financial regulators must level the playing field and promulgate rules that require non-traditional market lenders to meet basic consumer protection requirements such as those of TILA, underwriting standards for loans, and applicable state usury laws; FSOC should facilitate regulatory coordination among its member regulators; preserve the credit union tax exemption; regulatory relief including CFPB using their exemption authority more; Housing Finance Reform - it is vital that credit unions continue to have unfettered access to the secondary mortgage market and any reforms should have emphasis on fair pricing that reflects loan quality rather than quantity; Department of Labors proposed changes to the Fair Labor Standards Act for certain full-time salaried works to be eligible for overtime protections; Federal Communication Commission clarification for free end user calls made by financial institutions; Federal Communication Commission clarification regarding clarifications to the interpretations of the Telephone Consumer Protection Act; FCCs Declaratory Ruling and Order on TCPA; H.R. 1155: the Searching for and Cutting Regulations that are unnecessarily Burdensome (SCRUB) Act; prepaid cards - CFPB efforts to ensure that consumers using prepaid products are sufficiently informed and protected - they should find appropriate balance between adequate consumer protection and allowing consumers access to products they demand; compliance burdens related to CFPB amendments to Regulation C, HMDA; Uniform Residential Loan Application (URLA); Periodic Statements for Borrowers who have filed for bankruptcy; Statement production systems and CFPBs servicing regulations; Small Business Administration SBA 7(a) business loan program; H.R. 2499: Veterans Entrepreneurship Act of 2015; FY 2016 Financial Services and General Government Appropriations bill; H.R. 427: Regulations for the Executive in Need of Scrutiny Act of 2015; Improve agency use of regulatory guidance; Protect responsible overdraft services; Changes to requirements under the Home Mortgage Disclosure Act; H.R. 957: Bureau of Consumer Financial Protection Inspector General Reform Act; Reform of Fannie Mae and Freddie Mac; Credit risk-guarantee fees; Military Lending Act; H.R. 1735: National Defense Authorization Act for Fiscal Year 2016; Cost-benefit analysis at federal regulatory agencies; Regulatory coordination; Regulations related to remittance transfers; Legal opinion letters at the CFPB and NCUA; H.R. 9: Innovation Act; H.R. 185: Regulatory Accountability Act of 2015; H.R. 527: Small Business Regulatory Flexibility Improvements Act of 2015; H.R. 650: Preserving Access to Manufactured Housing Act; H.R. 766: Financial Institution Customer Protection Act/ Ending Operation Choke Point; H.R. 1262: Consumer Right to Financial Privacy Act of 2015; H.R. 1263: Consumer Financial Protection Safety and Soundness Improvement Act/ Changes veto authority of the Financial Stability Oversight Council; H.R. 1265: Bureau Advisory Commission Transparency Act/ Making credit union advisory council meetings public; H.R. 1266: Financial Product Safety Commission Act/ Replacing CFPB Director with Commission; H.R. 1309: Systemic Risk Designation Improvement Act of 2015; S. 881: Comprehensive Regulatory Review Act of 2015; S. 924: To require public hearings on NCUA's budget; S. 1137: PATENT Act; S. 1440: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; Ensure an Effective Payments system; Fairness under FCC ruling on autodialing and FCC oversight; Telephone Consumer Protection Act; modernize online lending laws and regulations; give NCUA greater flexibility with credit union lending including the ability to establish longer maturities for certain loans; preventing g-fees charged by Fannie and Freddie from being used as funding offset; NCUA 18-month Exam Cycle; Military Lending Act Database; Credit Losses Accounting Standard; FASB Accounting Standards; CFPBs expansion of data collection under Reg C, Privacy protections for data collected by CFPB; NIST notice and request for information on views on the Framework for Improving Critical Infrastructure Cybersecurity; Comments on Notice of proposed rulemaking regarding field of membership and chartering; CBSA population limit, combined statistical area, well defined local communities, rural population limits, multiple common bond charters, underserved areas, TIP charters; CFPB information collection on compliance costs and other effects of regulation; Duty to serve underserved markets; interchange rates as related to the Durbin Amendment to Dodd-Frank; Repeal Durbin Amendment; H.R. 5465 - to repeal Durbin Amendment; Federal Reserves EGRPRA review process; FHFAs principal reduction consideration; FFIEC Cybersecurity Assessment Tool; FFIEC proposed revision to the Uniform Interagency Consumer Compliance Rating System; Department of Labor Fiduciary Rule, Department of Labor overtime Rule; Administrative Procedures Act; Regulatory Flexibility for credit unions; Promote Consumer Protection and Financial Literacy; Financial Technology (FinTech); FinTech and online marketplace lending; Transparency for NCUAs Overhead Transfer Rate methodology; Transparency for NCUAs Operating Fee methodology; FY 2017 Financial Services and General Government Appropriations Bill; Community Development Financial Institution funding (CDFI); CDFI certification and reporting requirements; Dept. of Treasurys National Strategy for financial literacy and education; NCUAs information collection on investment and deposit activities; allow credit unions to purchase loans from other originators for purposes of issuing securities; mortgage servicing rights; extend exemption for consumer credit cards from MLA Rule requirements; Secondary Capital for low-income designated credit unions(LICU); LICU information collection burdens; Loan Level Price adjustments and Guaranty Fees; HR5541, Financial Services for the Underserved Act of 2016; NCUAs proposed rule regarding FCU occupancy, planning, and disposal of acquired and abandoned premises; HR 1486, Taking Account of Bureaucrats Spending Act (TABS); HR 4773, the Protection Workplace Advancement and Opportunity Act; HR 4538, the Senior$afe Act; NCUAs proposed rule on Incentive-Based Compensation Arrangement; NCUAs Exam Flexibility Initiative; issues related to the National Credit Union Share Insurance Funds Equity Ratio; NCUAs Regulatory Review; seeking guidance from NCUA on interpretation of overall financial performance; NCUAs Revised Examiner Guidance; NCUA to revise CUSO reporting requirements; CUSO accounting standards, Amend NCUA thresholds for supervisory committee audits and verifications; NCUA to address duplicative nature of Fair Credit Reporting regulations; Incidental Powers; requirements for share insurance; Update call reports; DOJs ANPR on accessibility of web information and services of State and Local Government entities; CFPBs amendment to Regulation Ps Annual Privacy Notice Requirement; NCUAs modernization of data collection for regulatory oversight of credit unions; CFPBs proposed rule on arbitration agreements; Property Assessed Clean Energy (PACE) Loans; NCUAs proposed amendments to the Community Development Revolving Loan Fund; modernization of Federal Credit union Bylaws; FHFAs development of a Common Securitization Platform; NIST request for comment on current and future states of cybersecurity in the digital economy; DOD to give better guidance and extend effective date on Military Lending Act Rule; comments on CFPBs Outline of Proposals Under Consideration and Alternatives Considered regarding Third-Party debt collection practices; comments on Consumer Response Company Response Survey; H.R. 5983, the Financial CHOICE Act; H.R. 4038, the Community Financial Institution Exemption Act; H.R. 6094, Regulatory Relief for Small Businesses, Schools, and Non-Profits Act.
2016 · third_quarter · Financial Institutions/Investments/Securities
Supplemental capital issues, regulatory issues for credit unions and tax exemption status: HR185; HR 766; HR 957; HR 1133; HR 1176; HR 1188; HR 1266; HR 1422; HR 1486; HR 1529; HR 1550; HR 1660; HR 1661; HR 1941; HR 2099; HR 2213; HR 2473; HR 2642; HR 2769;HR 2896; HR 3557; HR 3738; HR 3808; HR 3857; HR 4099; HR 4210; HR 4248; HR 4500; HR 4538; HR 4647; HR 4894; HR 4913; HR 4997; HR 5112; HR 5211; HR 5413; HR 5419; HR 5453; HR 5465; HR 5490; HR 5491; HR 5521; HR 5522; HR 5523; HR 5527; HR 5569; HR 5724; HR 5869; HR 5991; HR 6118; HR 6162; HR 6244; HR 6266; S. 423; S. 482; S. 726; S. 774; S. 924; S. 970; S. 1383; S. 1440; S. 1484; S. 1491; S. 2038; S. 2216; S. 2315; S. 2663; S. 2722; S. 2760; S. 2790; S. 2995; 2.3083; S. 3153; S. 3196; S. 3215; S. 3219; S. 3321; data security and cybersecurity; patent reform; FHLB membership rules; CFPB and FSOC reform; and GSE reform.
Client expense: Not reported · Firm income: $50,000
2016 · third_quarter · Banking
Issues related to credit union operations Issues related to credit union field of membership Issues related to credit union service organizations Issues related to vacancies on the National Credit Union Administration (NCUA) Board Issues related to NCUAs low income designation regulations Issues related to NCUA examination procedures Issues related to NCUAs regulation regarding its regulatory flexibility program Issues related to NCUAs proposed rule regarding emergency liquidity Issues related to NCUAs rulemaking process Issues related to material loss reports of the NCUA Office of Inspector General Issues related to the authority of the CFPB to exempt credit unions from its rulemaking Issues related to the CFPB proposal related to remittances and international wire transfers Issues related to the proposed CFPB form on RESPA/TILA Issues related to CFPBs Leadership Structure and Installing a Board Rather than Director Issues related to funding the CFPB through the Appropriations Process Issues related to increasing the CFPB Examination Threshold Issues related to conducting a cost-benefit analysis of all CFPB Proposals Issues related to codifying the CFPBs Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to standardizing the definition of mortgage originator Issues related to overdraft protection and check ordering practices Issues related to mortgage servicing Issues related to mortgage loan originator compensation and qualifications Issues related to high-cost mortgage loans (HOEPA) Issues related to the CFPBs proposed rule regarding qualified mortgage / ability to repay Issues related to reverse mortgages Issues related to the Financial Accounting Standards Board (FASB) Issues related to mark-to-market accounting Issues related to private equity standards Issues related to the implementation of the Unlawful Internet Gambling Prohibition Act Issues related to data and cyber security Issues related to mobile banking and mobile payments Issues related to the oversight of the Federal Housing Administration Issues related to USDA Rural Development Loan program Issues related to identity theft and fraud reduction Issues related to student lending Issues related to the Federal Home Loan Bank System Issues related to short term lending products and advance deposit products Issues related to patent reform Issues related to Federal Credit Union bylaws Issues relating to home-based credit unions Issues related to NCUAs risk-based capital proposal Issues related to NCUAs proposed rule on securitization Issues related to NCUAs regulatory review process Issues related to credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union by-laws Issues related to credit unions incidental powers Issues related to credit unions ability to offer prepaid cards Issues related to Ginnie Mae capital Issues related to credit union service to marijuana businesses Issues related to financial literacy Issues related to the Department of Justices investigation entitled, Operation Choke Point Issues related to membership eligibility in the Federal Home Loan Bank System. Issues related to the Department of Defense proposal regarding Credit Extending to Service Members under MLA Issues related to the Economic Growth and Regulatory Paperwork Reduction Act process Issues related to indirect auto lending Issues related to fixed assets Issues related to merchant data breaches Issues related to the payments system Issues related to FHFA proposed rules and FHLB eligibility for credit unions Issues related to Federal Reserve Regulatory D Issues related to 1-4 Family Non-Owner Occupied Residential Loan Treatment as Residential Rather than Business Loans Issues related to the use of Eminent Domain to Seize Performing Mortgage Loans Issues related to Housing Finance Reform Issues related to the implementation of the remittances provisions in the Dodd-Frank Act Issues related to NCUAs proposal rule on Member Business Lending Issues related to NCUAs proposed rule on Interest on Lawyer Trust Accounts (IOLTA) Issues related to credit union service to unbanked and underbanked consumers Issues related to the United States Postal Service Office of Inspector General report related to role of the postal service in financial services Issues related to the Feds implementation of same-day ACH Issues related to the regulation of corporate credit unions Issues related to the CFPBs proposed regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the payday, vehicle title, and similar lending Issues related to the CFPBs consumer complaint database Issues related to NCUAs Fixed Assets rule Issues related to NCUAs definition of small entity Issues related to NCUA's Proposed Rule on Member Business Lending Issues related to the Department of Labor's Proposed Rule on the Definition of Fiduciary Issues related to the Telephone Consumer Protection Act Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements Issues related to the Department of Labor's Proposed Overtime Eligibility rule Issues related to credit union conversions Issues related to the CFPB's proposal on arbitration Issues related to secure payments Issues related to credit union call report modernization H.R. 9, the Innovation Act, all provisions H.R. 22, the FAST Act, Title LXXV, provisions related to privacy notice requirements; Title LXXXII, provisions related to the eligibility of privately insured credit unions to join a Federal Home Loan Bank; Title LXXXIX, provisions related to the designation of rural areas by the Consumer Financial Protection Bureau H.R. 185, Regulatory Accountability Act of 2015 H.R. 299, the Capital Access for Small Community Financial Institutions Act of 2015, all provisions H.R. 527, the Small Business Regulatory Flexibility Improvements Act of 2015 H.R. 601, the Eliminate Privacy Notice Confusion Act, all provisions H.R. 650, Preserving Access to Manufactured Housing Act, all provision H.R. 685, the Mortgage Choice Act, all provisions H.R. 766, Financial Institution Consumer Protection Act, all provisions H.R. 957, the Bureau of Consumer Financial Protection Inspector General Reform Act, all provisions H.R. 989, the Capital Access for Small Businesses Jobs Creation Act, all provisions H.R. 1090, Retail Investor Protection Act, all provisions H.R. 1176, the NCUA Budget Transparency Act, all provisions H.R. 1188, the Credit Union Small Business Jobs Creation Act, all provisions H.R. 1195, the Bureau of Consumer Financial Protection Advisory Boards Act, all provisions H.R. 1210, the Portfolio Lending and Mortgage Access Act, H.R. 1233, the Community Lending Enhancement and Regulatory Relief Act of 2015 H.R. 1259, the Helping Expand Lending Practices in Rural Communities Act, all provisions H.R. 1263, Consumer Financial Protection Safety and Soundness Improvement Act of 2015 H.R. 1265, the Bureau Advisory Commission Transparency Act, all provision H.R. 1266, the Financial Products Safety Commission Act of 2015 H.R. 1408, requiring a study of the capital requirements for mortgage servicing assets H.R. 1422, the Credit Union Residential Loan Parity Act H.R. 1480, the SAFE Confidentiality and Privilege Enhancement Act H.R. 1523, Community Bank Access to Capital Act of 2015 H.R. 1529, the Community Institution Mortgage Relief Act Discussion Draft, Data Security and Breach Notification Act of 2015 H.R. 1660, the Federal Savings Association Charter Flexibility Act, all provisions H.R. 1941, the Financial Institution Examination Fairness and Reform Act H.R. 2205, the Data Security Act H.R. 2213, to provide for a temporary safe harbor from the enforcement of integrated disclosure requirements for mortgage loan transactions under the Real Estate Settlement Procedures Act of 1974 and the Truth in Lending Act, and for other purposes. H.R. 2287, the National Credit Union Administration Budget Transparency Act H.R. 2473, the Preserving Capital Access and Mortgage Liquidity Act H.R. 2769, the Risk-Based Capital Study Act, all provisions H.R. 2896, the Taking Account of Institutions with Low Operation Risk (TAILOR) Act H.R. 3192, the Homebuyer Assistance Act, all provisions H.R. 4638, the Senior $afe Act, all provisions H.R. 4893, the Risk Management and Homeowner Stability Act, all provisions H.R. 4997, the Home Mortgage Disclosure Adjustment Act, all provisions H.R. 5465, a bill to repeal section 1075 of the Consumer Financial Protection Act of 2010 relating to rules for payment card transactions, all provisions H.R. 5983, the Financial CHOICE Act, all provisions S. 423, the Privacy Notice Modernization Act, all provisions S. 482, the Consumer Financial Protection Bureau Examination Reporting Threshold Act of 2015, all provisions S. 774 Financial Institutions Examination Fairness and Reform Act, all provisions S. 871, the Helping Expand Lending Practices in (HELP) Rural Communities Act S. 924, the National Credit Union Administration Budget Transparency Act S. 961, the Data Security Act S. 1367, a bill to amend the Federal Home Loan Bank Act with respect to membership eligibility of certain institutions S. 1440, the Credit Union Residential Loan Parity Act S. 1484, the Financial Regulatory Improvement Act, Title I S. 2216, the Senior$afe Act, all provisions The Heck-Stivers Amendment to H.R. 1735, the National Defense Authorization Act, related to the Department of Defenses MLA Database Discussion draft of the Financial Creating Hope and Opportunity for Investors, Consumers and Entrepreneurs (CHOICE) Act, all provisions
2016 · third_quarter · Banking
H.R. 989, supplemental capital. H.R. 1188 member business lending. H.R. 1133 veterans exemption to member business lending cap. H.R. 299 privately insured credit unions. H.R. 601 privacy notifications.H.R. 1422 residential parity. H.R. 2679, risk based capital stop and study act. S. 1484, regulatory relief. S.2028, member business lending. S. 1440, residential parity. S. 961, data security. Merchant data breaches as they apply to financial institutions. EMV chip-card conversions. National Credit Union Administration and Consumer Financial Protection Bureau regulatory issues. Proposed rules on Field of Membership and Member Business Lending. Credit union examinations. Risk-based capital. Truth in lending disclosures (TRID). HMDA Home Mortgage Disclosure Act. Community lender exemption authority to Dodd-Frank Wall Street Reform and Consumer Protection Act. Property Assessed Clean Energy (PACE) lending and priority liens. Fair Credit Reporting Act - Federal Trade Commission.
Client expense: $110,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), SENATE
2016 · second_quarter · Financial Institutions/Investments/Securities
Supplemental capital issues, regulatory issues for credit unions and tax exemption status: HR185; HR 766; HR 957; HR 989; HR 1133; HR 1176; HR 1188; HR 1266; HR 1422; HR 1486; HR 1491; HR 1529; HR 1550; HR 1660; HR 1661; HR 1941; HR 2099; HR 2213; HR 2473; HR 2477; HR 2642; HR 2769;HR 2896; HR 3557; HR 3738; HR 3808; HR 3857; HR 4099; HR 4166; HR 4210; HR 4248; HR 4347; HR 4500; HR 4538; HR 4620; HR 4647; HR 4781; HR 4894; HR 4913; HR 4997; HR 5112; HR 5211; HR 5413; HR 5419; HR 5453; HR 5465; HR 5490; HR 5491; HR 5521; HR 5522; HR 5523; HR 5527; HR 5569; S. 423; S. 482; S. 726; S. 774; S. 924; S. 970; S. 1383; S. 1440; S. 1484; S. 1491; S. 2028; S. 2038; S. 2216; S. 2315; S.2663; S 2722; data security and cybersecurity; patent reform; FHLB membership rules; CFPB and FSOC reform; and GSE reform.
Client expense: Not reported · Firm income: $50,000
2016 · second_quarter · Banking
Issues related to credit union operations Issues related to credit union field of membership Issues related to credit union service organizations Issues related to vacancies on the National Credit Union Administration (NCUA) Board Issues related to NCUAs low income designation regulations Issues related to NCUA examination procedures Issues related to NCUAs regulation regarding its regulatory flexibility program Issues related to NCUAs proposed rule regarding emergency liquidity Issues related to NCUAs rulemaking process Issues related to material loss reports of the NCUA Office of Inspector General Issues related to the authority of the CFPB to exempt credit unions from its rulemaking Issues related to the CFPB proposal related to remittances and international wire transfers Issues related to the proposed CFPB form on RESPA/TILA Issues related to CFPBs Leadership Structure and Installing a Board Rather than Director Issues related to funding the CFPB through the Appropriations Process Issues related to increasing the CFPB Examination Threshold Issues related to conducting a cost-benefit analysis of all CFPB Proposals Issues related to codifying the CFPBs Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to standardizing the definition of mortgage originator Issues related to overdraft protection and check ordering practices Issues related to mortgage servicing Issues related to mortgage loan originator compensation and qualifications Issues related to high-cost mortgage loans (HOEPA) Issues related to the CFPBs proposed rule regarding qualified mortgage / ability to repay Issues related to reverse mortgages Issues related to the Financial Accounting Standards Board (FASB) Issues related to mark-to-market accounting Issues related to private equity standards Issues related to the implementation of the Unlawful Internet Gambling Prohibition Act Issues related to data and cyber security Issues related to mobile banking and mobile payments Issues related to the oversight of the Federal Housing Administration Issues related to USDA Rural Development Loan program Issues related to identity theft and fraud reduction Issues related to student lending Issues related to the Federal Home Loan Bank System Issues related to short term lending products and advance deposit products Issues related to patent reform Issues related to Federal Credit Union bylaws Issues relating to home-based credit unions Issues related to NCUAs risk-based capital proposal Issues related to NCUAs proposed rule on securitization Issues related to NCUAs regulatory review process Issues related to credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union by-laws Issues related to credit unions incidental powers Issues related to credit unions ability to offer prepaid cards Issues related to Ginnie Mae capital Issues related to credit union service to marijuana businesses Issues related to financial literacy Issues related to the Department of Justices investigation entitled, Operation Choke Point Issues related to membership eligibility in the Federal Home Loan Bank System. Issues related to the Department of Defense proposal regarding Credit Extending to Service Members under MLA Issues related to the Economic Growth and Regulatory Paperwork Reduction Act process Issues related to indirect auto lending Issues related to fixed assets Issues related to merchant data breaches Issues related to the payments system Issues related to FHFA proposed rules and FHLB eligibility for credit unions Issues related to Federal Reserve Regulatory D Issues related to 1-4 Family Non-Owner Occupied Residential Loan Treatment as Residential Rather than Business Loans Issues related to the use of Eminent Domain to Seize Performing Mortgage Loans Issues related to Housing Finance Reform Issues related to the implementation of the remittances provisions in the Dodd-Frank Act Issues related to NCUAs proposal rule on Member Business Lending Issues related to NCUAs proposed rule on Interest on Lawyer Trust Accounts (IOLTA) Issues related to credit union service to unbanked and underbanked consumers Issues related to the United States Postal Service Office of Inspector General report related to role of the postal service in financial services Issues related to the Feds implementation of same-day ACH Issues related to the regulation of corporate credit unions Issues related to the CFPBs proposed regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the payday, vehicle title, and similar lending Issues related to the CFPBs consumer complaint database Issues related to NCUAs Fixed Assets rule Issues related to NCUAs definition of small entity Issues related to NCUA's Proposed Rule on Member Business Lending Issues related to the Department of Labor's Proposed Rule on the Definition of Fiduciary Issues related to the Telephone Consumer Protection Act Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements Issues related to the Department of Labor's Proposed Overtime Eligibility rule Issues related to credit union conversions Issues related to the CFPB's proposal on arbitration Issues related to secure payments Issues related to credit union call report modernization H.R. 9, the Innovation Act, all provisions H.R. 22, the FAST Act, Title LXXV, provisions related to privacy notice requirements; Title LXXXII, provisions related to the eligibility of privately insured credit unions to join a Federal Home Loan Bank; Title LXXXIX, provisions related to the designation of rural areas by the Consumer Financial Protection Bureau H.R. 185, Regulatory Accountability Act of 2015 H.R. 299, the Capital Access for Small Community Financial Institutions Act of 2015, all provisions H.R. 527, the Small Business Regulatory Flexibility Improvements Act of 2015 H.R. 601, the Eliminate Privacy Notice Confusion Act, all provisions H.R. 650, Preserving Access to Manufactured Housing Act, all provision H.R. 685, the Mortgage Choice Act, all provisions H.R. 766, Financial Institution Consumer Protection Act, all provisions H.R. 957, the Bureau of Consumer Financial Protection Inspector General Reform Act, all provisions H.R. 989, the Capital Access for Small Businesses Jobs Creation Act, all provisions H.R. 1090, Retail Investor Protection Act, all provisions H.R. 1176, the NCUA Budget Transparency Act, all provisions H.R. 1188, the Credit Union Small Business Jobs Creation Act, all provisions H.R. 1195, the Bureau of Consumer Financial Protection Advisory Boards Act, all provisions H.R. 1210, the Portfolio Lending and Mortgage Access Act, H.R. 1233, the Community Lending Enhancement and Regulatory Relief Act of 2015 H.R. 1259, the Helping Expand Lending Practices in Rural Communities Act, all provisions H.R. 1263, Consumer Financial Protection Safety and Soundness Improvement Act of 2015 H.R. 1265, the Bureau Advisory Commission Transparency Act, all provision H.R. 1266, the Financial Products Safety Commission Act of 2015 H.R. 1408, requiring a study of the capital requirements for mortgage servicing assets H.R. 1422, the Credit Union Residential Loan Parity Act H.R. 1480, the SAFE Confidentiality and Privilege Enhancement Act H.R. 1523, Community Bank Access to Capital Act of 2015 H.R. 1529, the Community Institution Mortgage Relief Act Discussion Draft, Data Security and Breach Notification Act of 2015 H.R. 1660, the Federal Savings Association Charter Flexibility Act, all provisions H.R. 1941, the Financial Institution Examination Fairness and Reform Act H.R. 2205, the Data Security Act H.R. 2213, to provide for a temporary safe harbor from the enforcement of integrated disclosure requirements for mortgage loan transactions under the Real Estate Settlement Procedures Act of 1974 and the Truth in Lending Act, and for other purposes. H.R. 2287, the National Credit Union Administration Budget Transparency Act H.R. 2473, the Preserving Capital Access and Mortgage Liquidity Act H.R. 2769, the Risk-Based Capital Study Act, all provisions H.R. 2896, the Taking Account of Institutions with Low Operation Risk (TAILOR) Act H.R. 3192, the Homebuyer Assistance Act, all provisions H.R. 4893, the Risk Management and Homeowner Stability Act, all provisions H.R. 5465, a bill to repeal section 1075 of the Consumer Financial Protection Act of 2010 relating to rules for payment card transactions, all provisions S. 423, the Privacy Notice Modernization Act, all provisions S. 482, the Consumer Financial Protection Bureau Examination Reporting Threshold Act of 2015, all provisions S. 774 Financial Institutions Examination Fairness and Reform Act, all provisions S. 871, the Helping Expand Lending Practices in (HELP) Rural Communities Act S. 924, the National Credit Union Administration Budget Transparency Act S. 961, the Data Security Act S. 1367, a bill to amend the Federal Home Loan Bank Act with respect to membership eligibility of certain institutions S. 1440, the Credit Union Residential Loan Parity Act S. 1484, the Financial Regulatory Improvement Act, Title I S. 2216, the Senior$afe Act, all provisions The Heck-Stivers Amendment to H.R. 1735, the National Defense Authorization Act, related to the Department of Defenses MLA Database Discussion draft of the Financial Creating Hope and Opportunity for Investors, Consumers and Entrepreneurs (CHOICE) Act, all provisions
2016 · second_quarter · Financial Institutions/Investments/Securities
Consumer Financial Protection Bureaus (CFPB) Notice and Request for Comment on Web-Based Quantitative Testing Point of Sale/ATM (POS/ATM) Overdraft Disclosure Forms; Comments responding to request for information on the FHFAs proposed collection of information relating to the NSEMB; Comments on Regulatory Impact Assessment and Initial Regulatory Flexibility Analysis, RIN 1506-AB25; Concerns with CFPB future payday lending rulemakings; payday lending as related to the CFPB Proposals; H.R. 3192: Homebuyers Assistance Act; H.R. 2769: Risk-Based Capital Study Act; National Credit Union Administrations (NCUA) risk-based capital proposal; H.R. 2205: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; NCUA budget transparency; H.R. 1176: NCUA Budget Transparency Act/ GAO Study of NCUA budgeting practices; H.R. 1188: Credit Union Small Business Jobs Creation Act/ raising MBL cap; H.R. 1195: Bureau of Consumer Financial Protection Advisory Boards Act; H.R. 1210: Portfolio Lending and Mortgage Access Act; H.R. 2473: Preserving Capital Access and Mortgage Liquidity Act of 2015; H.R. 2896: the TAILOR Act of 2015; S. 754: Cyber Security Information Sharing Act; NAFCUs Five Point Plan for Regulatory Relief (capital reforms for credit unions; field of membership improvements for credit unions; reduced consumer financial protection bureaus on credit unions; operational improvements for credit unions; 21st century data security standards); Regulatory relief for credit unions; S. 961: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; NCUAs efforts to allow credit unions to better serve rural areas; H.R. 1259: Helping Expand Lending Practices in Rural Communities Act; CFPBs inerim final rule amending Regulation Z; H.R. 1261: Bureau of Consumer Financial Protection Accountability Act/ Subjects CFPB to Congressional appropriations process; S. 774: Financial Institutions Examination Fairness and Reform Act; S. 871: HELP Rural Communities Act of 2015/ CFPB Rural Definition; H.R. 685: Mortgage Choice Act of 2015/ Points and Fees; H.R. 1408: Mortgage Servicing Asset Capital Requirements Act; H.R. 1422: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; H.R. 1529: Community Institution Mortgage Relief Act of 2015; H.R. 1941: Financial Institutions Examination Fairness and Reform Act; Regulatory Burdens; Qualified Mortgage Rule; S. 1484: Financial Regulatory Improvement Act; Federal Credit Union Act; S. 2028: A bill to amend the Federal Credit Union Act, to advance the ability of credit unions to promote small business growth and economic development opportunities, and for other purposes; H.R. 3738: the Office of Financial Research Accountability Act of 2015; H.R. 3557: the FSOC Transparency and Accountability Act; H.R. 1660: the Federal Savings Association Charter Flexibility Act; Improve the federal charter of credit unions through the FCU Act; H.R. 989: Capital Access for Small Businesses and Jobs Act/ Supplemental Capital; H.R. 1133: To exclude extensions of credit made to veterans from the definition of a member business loan under the Federal Credit Union Act; NCUA proposed rulemaking on a federal insured credit unions member business lending; NCUAs exam scheduling policy; NAFCUs Top Ten Regulations for Eliminate of Amend (improve process for credit unions seeking changes to their field of membership; provide more meaningful exemptions for small institutions; Dodd-Frank 1022 Authority; expand credit union investment authority; allowing more transfers per month from savings accounts per Federal Reserve Regulation D; flexibility for credit unions making member business loans; NCUAs member business lending rule: update requirement to disclose account numbers to protect privacy of members; update advertising requirements for loan products and share accounts; seek improvements to the NCUA Central Liquidity Facility (CLF); CLF information collection; CLF modernizationobtain flexibility for federal credit unions to determine their choice of law; update simplify and make improvements to regulations governing check processing funds); S. 423: Privacy Notice Modernization Act of 2015; H.R. 22: the Surface Transportation Reauthorization and Reform Act of 2015; NCUAs proposed Field of Membership Amendments; H.R. 2995: Financial Services and General Government Appropriations Act; Require the CFPB to conduct a fair, comprehensive study before adopting a rule that would restrict arbitration and open the door to abusive class actions; prevent arbitration restrictions; NCUA third party vendor authority; CFPB request for approval under the Paperwork Reduction Act to conduct a national web-based survey relative to overdraft protection services; CFPB consumer complaint narrative database; CFPB and the student loan servicing market; Student Loan Borrower Communication ;CFPB integration of the Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) disclosures, consider good faith efforts to comply with TRID; financial regulators must level the playing field and promulgate rules that require non-traditional market lenders to meet basic consumer protection requirements such as those of TILA, underwriting standards for loans, and applicable state usury laws; FSOC should facilitate regulatory coordination among its member regulators; preserve the credit union tax exemption; regulatory relief including CFPB using their exemption authority more; Housing Finance Reform - it is vital that credit unions continue to have unfettered access to the secondary mortgage market and any reforms should have emphasis on fair pricing that reflects loan quality rather than quantity; Department of Labors proposed changes to the Fair Labor Standards Act for certain full-time salaried works to be eligible for overtime protections; Federal Communication Commission clarification for free end user calls made by financial institutions; Federal Communication Commission clarification regarding clarifications to the interpretations of the Telephone Consumer Protection Act; H.R. 1155: the Searching for and Cutting Regulations that are unnecessarily Burdensome (SCRUB) Act; prepaid cards - CFPB efforts to ensure that consumers using prepaid products are sufficiently informed and protected - they should find appropriate balance between adequate consumer protection and allowing consumers access to products they demand; compliance burdens related to CFPB amendments to Regulation C, HMDA; Uniform Residential Loan Application (URLA); Periodic Statements for Borrowers who have filed for bankruptcy; Statement production systems and CFPBs servicing regulations; Small Business Administration SBA 7(a) business loan program; H.R. 2499: Veterans Entrepreneurship Act of 2015; FY 2016 Financial Services and General Government Appropriations bill; H.R. 427: Regulations for the Executive in Need of Scrutiny Act of 2015; Improve agency use of regulatory guidance; Protect responsible overdraft services; Changes to requirements under the Home Mortgage Disclosure Act; H.R. 957: Bureau of Consumer Financial Protection Inspector General Reform Act; Reform of Fannie Mae and Freddie Mac; Credit risk-guarantee fees; Military Lending Act; H.R. 1735: National Defense Authorization Act for Fiscal Year 2016; Cost-benefit analysis at federal regulatory agencies; Regulatory coordination; Regulations related to remittance transfers; Legal opinion letters at the CFPB and NCUA; H.R. 9: Innovation Act; H.R. 185: Regulatory Accountability Act of 2015; H.R. 527: Small Business Regulatory Flexibility Improvements Act of 2015; H.R. 650: Preserving Access to Manufactured Housing Act; H.R. 766: Financial Institution Customer Protection Act/ Ending Operation Choke Point; H.R. 1262: Consumer Right to Financial Privacy Act of 2015; H.R. 1263: Consumer Financial Protection Safety and Soundness Improvement Act/ Changes veto authority of the Financial Stability Oversight Council; H.R. 1265: Bureau Advisory Commission Transparency Act/ Making credit union advisory council meetings public; H.R. 1266: Financial Product Safety Commission Act/ Replacing CFPB Director with Commission; H.R. 1309: Systemic Risk Designation Improvement Act of 2015; S. 881: Comprehensive Regulatory Review Act of 2015; S. 924: To require public hearings on NCUA's budget; S. 1137: PATENT Act; S. 1440: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; Ensure an Effective Payments system; Fairness under FCC ruling on autodialing and FCC oversight; Telephone Consumer Protection Act; modernize online lending laws and regulations; give NCUA greater flexibility with credit union lending including the ability to establish longer maturities for certain loans; preventing g-fees charged by Fannie and Freddie from being used as funding offset; NCUA 18-month Exam Cycle; Military Lending Act Database; Credit Losses Accounting Standard; FASB Accounting Standards; CFPBs expansion of data collection under Reg C, Privacy protections for data collected by CFPB; NIST notice and request for information on views on the Framework for Improving Critical Infrastructure Cybersecurity; Comments on Notice of proposed rulemaking regarding field of membership and chartering; CBSA population limit, combined statistical area, well defined local communities, rural population limits, multiple common bond charters, underserved areas, TIP charters; CFPB information collection on compliance costs and other effects of regulation; Duty to serve underserved markets; interchange rates as related to the Durbin Amendment to Dodd-Frank; Repeal Durbin Amendment; Federal Reserves EGRPRA review process; FHFAs principal reduction consideration; FFIEC Cybersecurity Assessment Tool; Department of Labor Fiduciary Rule, Department of Labor overtime Rule; Administrative Procedures Act; Regulatory Flexibility for credit unions; Promote Consumer Protection and Financial Literacy; Financial Technology (FinTech); Transparency for NCUAs Overhead Transfer Rate methodology; Transparency for NCUAs Operating Fee methodology; FY 2017 Financial Services and General Government Appropriations Bill; Community Development Financial Institution funding (CDFI); CDFI certification and reporting requirements; Dept. of Treasurys National Strategy for financial literacy and education; NCUAs information collection on investment and deposit activities; allow credit unions to purchase loans from other originators for purposes of issuing securities; mortgage servicing rights; extend exemption for consumer credit cards from MLA Rule requirements; Secondary Capital for low-income designated credit unions(LICU); LICU information collection burdens; Loan Level Price adjustments and Guaranty Fees; HR5541, Financial Services for the Underserved Act of 2016; NCUAs proposed rule regarding FCU occupancy, planning, and disposal of acquired and abandoned premises; HR 1486, Taking Account of Bureaucrats Spending Act (TABS); HR 4773, the Protection Workplace Advancement and Opportunity Act; HR 4538, the Senior$afe Act.
2016 · second_quarter · Banking
Consumer Financial Protection Bureaus (CFPB) Notice and Request for Comment on Web-Based Quantitative Testing Point of Sale/ATM (POS/ATM) Overdraft Disclosure Forms; Comments responding to request for information on the FHFAs proposed collection of information relating to the NSEMB; Comments on Regulatory Impact Assessment and Initial Regulatory Flexibility Analysis, RIN 1506-AB25; Concerns with CFPB future payday lending rulemakings; payday lending as related to the CFPB Proposals; H.R. 3192: Homebuyers Assistance Act; H.R. 2769: Risk-Based Capital Study Act; National Credit Union Administrations (NCUA) risk-based capital proposal; H.R. 2205: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; NCUA budget transparency; H.R. 1176: NCUA Budget Transparency Act/ GAO Study of NCUA budgeting practices; H.R. 1188: Credit Union Small Business Jobs Creation Act/ raising MBL cap; H.R. 1195: Bureau of Consumer Financial Protection Advisory Boards Act; H.R. 1210: Portfolio Lending and Mortgage Access Act; H.R. 2473: Preserving Capital Access and Mortgage Liquidity Act of 2015; H.R. 2896: the TAILOR Act of 2015; S. 754: Cyber Security Information Sharing Act; NAFCUs Five Point Plan for Regulatory Relief (capital reforms for credit unions; field of membership improvements for credit unions; reduced consumer financial protection bureaus on credit unions; operational improvements for credit unions; 21st century data security standards); Regulatory relief for credit unions; S. 961: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; NCUAs efforts to allow credit unions to better serve rural areas; H.R. 1259: Helping Expand Lending Practices in Rural Communities Act; CFPBs inerim final rule amending Regulation Z; H.R. 1261: Bureau of Consumer Financial Protection Accountability Act/ Subjects CFPB to Congressional appropriations process; S. 774: Financial Institutions Examination Fairness and Reform Act; S. 871: HELP Rural Communities Act of 2015/ CFPB Rural Definition; H.R. 685: Mortgage Choice Act of 2015/ Points and Fees; H.R. 1408: Mortgage Servicing Asset Capital Requirements Act; H.R. 1422: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; H.R. 1529: Community Institution Mortgage Relief Act of 2015; H.R. 1941: Financial Institutions Examination Fairness and Reform Act; Regulatory Burdens; Qualified Mortgage Rule; S. 1484: Financial Regulatory Improvement Act; Federal Credit Union Act; S. 2028: A bill to amend the Federal Credit Union Act, to advance the ability of credit unions to promote small business growth and economic development opportunities, and for other purposes; H.R. 3738: the Office of Financial Research Accountability Act of 2015; H.R. 3557: the FSOC Transparency and Accountability Act; H.R. 1660: the Federal Savings Association Charter Flexibility Act; Improve the federal charter of credit unions through the FCU Act; H.R. 989: Capital Access for Small Businesses and Jobs Act/ Supplemental Capital; H.R. 1133: To exclude extensions of credit made to veterans from the definition of a member business loan under the Federal Credit Union Act; NCUA proposed rulemaking on a federal insured credit unions member business lending; NCUAs exam scheduling policy; NAFCUs Top Ten Regulations for Eliminate of Amend (improve process for credit unions seeking changes to their field of membership; provide more meaningful exemptions for small institutions; Dodd-Frank 1022 Authority; expand credit union investment authority; allowing more transfers per month from savings accounts per Federal Reserve Regulation D; flexibility for credit unions making member business loans; NCUAs member business lending rule: update requirement to disclose account numbers to protect privacy of members; update advertising requirements for loan products and share accounts; seek improvements to the NCUA Central Liquidity Facility (CLF); CLF information collection; CLF modernizationobtain flexibility for federal credit unions to determine their choice of law; update simplify and make improvements to regulations governing check processing funds); S. 423: Privacy Notice Modernization Act of 2015; H.R. 22: the Surface Transportation Reauthorization and Reform Act of 2015; NCUAs proposed Field of Membership Amendments; H.R. 2995: Financial Services and General Government Appropriations Act; Require the CFPB to conduct a fair, comprehensive study before adopting a rule that would restrict arbitration and open the door to abusive class actions; prevent arbitration restrictions; NCUA third party vendor authority; CFPB request for approval under the Paperwork Reduction Act to conduct a national web-based survey relative to overdraft protection services; CFPB consumer complaint narrative database; CFPB and the student loan servicing market; Student Loan Borrower Communication ;CFPB integration of the Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) disclosures, consider good faith efforts to comply with TRID; financial regulators must level the playing field and promulgate rules that require non-traditional market lenders to meet basic consumer protection requirements such as those of TILA, underwriting standards for loans, and applicable state usury laws; FSOC should facilitate regulatory coordination among its member regulators; preserve the credit union tax exemption; regulatory relief including CFPB using their exemption authority more; Housing Finance Reform - it is vital that credit unions continue to have unfettered access to the secondary mortgage market and any reforms should have emphasis on fair pricing that reflects loan quality rather than quantity; Department of Labors proposed changes to the Fair Labor Standards Act for certain full-time salaried works to be eligible for overtime protections; Federal Communication Commission clarification for free end user calls made by financial institutions; Federal Communication Commission clarification regarding clarifications to the interpretations of the Telephone Consumer Protection Act; H.R. 1155: the Searching for and Cutting Regulations that are unnecessarily Burdensome (SCRUB) Act; prepaid cards - CFPB efforts to ensure that consumers using prepaid products are sufficiently informed and protected - they should find appropriate balance between adequate consumer protection and allowing consumers access to products they demand; compliance burdens related to CFPB amendments to Regulation C, HMDA; Uniform Residential Loan Application (URLA); Periodic Statements for Borrowers who have filed for bankruptcy; Statement production systems and CFPBs servicing regulations; Small Business Administration SBA 7(a) business loan program; H.R. 2499: Veterans Entrepreneurship Act of 2015; FY 2016 Financial Services and General Government Appropriations bill; H.R. 427: Regulations for the Executive in Need of Scrutiny Act of 2015; Improve agency use of regulatory guidance; Protect responsible overdraft services; Changes to requirements under the Home Mortgage Disclosure Act; H.R. 957: Bureau of Consumer Financial Protection Inspector General Reform Act; Reform of Fannie Mae and Freddie Mac; Credit risk-guarantee fees; Military Lending Act; H.R. 1735: National Defense Authorization Act for Fiscal Year 2016; Cost-benefit analysis at federal regulatory agencies; Regulatory coordination; Regulations related to remittance transfers; Legal opinion letters at the CFPB and NCUA; H.R. 9: Innovation Act; H.R. 185: Regulatory Accountability Act of 2015; H.R. 527: Small Business Regulatory Flexibility Improvements Act of 2015; H.R. 650: Preserving Access to Manufactured Housing Act; H.R. 766: Financial Institution Customer Protection Act/ Ending Operation Choke Point; H.R. 1262: Consumer Right to Financial Privacy Act of 2015; H.R. 1263: Consumer Financial Protection Safety and Soundness Improvement Act/ Changes veto authority of the Financial Stability Oversight Council; H.R. 1265: Bureau Advisory Commission Transparency Act/ Making credit union advisory council meetings public; H.R. 1266: Financial Product Safety Commission Act/ Replacing CFPB Director with Commission; H.R. 1309: Systemic Risk Designation Improvement Act of 2015; S. 881: Comprehensive Regulatory Review Act of 2015; S. 924: To require public hearings on NCUA's budget; S. 1137: PATENT Act; S. 1440: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; Ensure an Effective Payments system; Fairness under FCC ruling on autodialing and FCC oversight; Telephone Consumer Protection Act; modernize online lending laws and regulations; give NCUA greater flexibility with credit union lending including the ability to establish longer maturities for certain loans; preventing g-fees charged by Fannie and Freddie from being used as funding offset; NCUA 18-month Exam Cycle; Military Lending Act Database; Credit Losses Accounting Standard; FASB Accounting Standards; CFPBs expansion of data collection under Reg C, Privacy protections for data collected by CFPB; NIST notice and request for information on views on the Framework for Improving Critical Infrastructure Cybersecurity; Comments on Notice of proposed rulemaking regarding field of membership and chartering; CBSA population limit, combined statistical area, well defined local communities, rural population limits, multiple common bond charters, underserved areas, TIP charters; CFPB information collection on compliance costs and other effects of regulation; Duty to serve underserved markets; interchange rates as related to the Durbin Amendment to Dodd-Frank; Repeal Durbin Amendment; Federal Reserves EGRPRA review process; FHFAs principal reduction consideration; FFIEC Cybersecurity Assessment Tool; Department of Labor Fiduciary Rule, Department of Labor overtime Rule; Administrative Procedures Act; Regulatory Flexibility for credit unions; Promote Consumer Protection and Financial Literacy; Financial Technology (FinTech); Transparency for NCUAs Overhead Transfer Rate methodology; Transparency for NCUAs Operating Fee methodology; FY 2017 Financial Services and General Government Appropriations Bill; Community Development Financial Institution funding (CDFI); CDFI certification and reporting requirements; Dept. of Treasurys National Strategy for financial literacy and education; NCUAs information collection on investment and deposit activities; allow credit unions to purchase loans from other originators for purposes of issuing securities; mortgage servicing rights; extend exemption for consumer credit cards from MLA Rule requirements; Secondary Capital for low-income designated credit unions(LICU); LICU information collection burdens; Loan Level Price adjustments and Guaranty Fees; HR5541, Financial Services for the Underserved Act of 2016; NCUAs proposed rule regarding FCU occupancy, planning, and disposal of acquired and abandoned premises; HR 1486, Taking Account of Bureaucrats Spending Act (TABS); HR 4773, the Protection Workplace Advancement and Opportunity Act; HR 4538, the Senior$afe Act.
2016 · second_quarter · Banking
H.R. 989, supplemental capital. H.R. 1188 member business lending. H.R. 1133 veterans exemption to member business lending cap. H.R. 299 privately insured credit unions. H.R. 601 privacy notifications.H.R. 1422 residential parity. H.R. 2679, risk based capital stop and study act. S. 1484, regulatory relief. S.2028, member business lending. S. 1440, residential parity. S. 961, data security. Merchant data breaches as they apply to financial institutions. EMV chip-card conversions. National Credit Union Administration and Consumer Financial Protection Bureau regulatory issues. Proposed rules on Field of Membership and Member Business Lending. Credit union examinations. Risk-based capital. Truth in lending disclosures (TRID). HMDA Home Mortgage Disclosure Act. Community lender exemption authority to Dodd-Frank Wall Street Reform and Consumer Protection Act. Property Assessed Clean Energy (PACE) lending and priority liens.
Client expense: $110,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), SENATE
2016 · first_quarter · Financial Institutions/Investments/Securities
Supplemental capital issues, regulatory issues for credit unions and tax exemption status: HR185; HR 299; HR 601; HR 685; HR 766; HR 957; HR 989; HR 1133; HR 1176; HR 1188; HR 1195; HR 1233; HR 1266; HR 1422; HR 1486; HR 1491; HR 1529; HR 1550; HR 1659; HR 1660; HR 1661; HR 1941; HR 2099; HR 2213; HR 2473; HR 2477; HR 2642; HR 2769;HR 2896; HR 3192; HR 3557; HR 3700; HR 3738; HR 3808; HR 3857; HR 4099; HR 4166; HR 4210; HR 4248; S. 423; S. 482; S. 726; S. 774; S. 924; S. 970; S. 1383; S. 1440; S. 1484; S. 1491; S. 2006; S. 2028; S. 2038; S. 2216; S. 2315; S. 2497; S. 2716 data security and cybersecurity; patent reform; FHLB membership rules; CFPB and FSOC reform; and GSE reform.
Client expense: Not reported · Firm income: $50,000
2016 · first_quarter · Financial Institutions/Investments/Securities
Consumer Financial Protection Bureaus (CFPB) Notice and Request for Comment on Web-Based Quantitative Testing Point of Sale/ATM (POS/ATM) Overdraft Disclosure Forms; Comments responding to request for information on the FHFAs proposed collection of information relating to the NSEMB; Comments on Regulatory Impact Assessment and Initial Regulatory Flexibility Analysis, RIN 1506-AB25; Concerns with CFPB future payday lending rulemakings; payday lending as related to the CFPBs Outline of Proposals Under Consideration; H.R. 3192: Homebuyers Assistance Act; H.R. 2769: Risk-Based Capital Study Act; National Credit Union Administrations (NCUA) risk-based capital proposal; H.R. 2205: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; NCUA budget transparency; H.R. 1176: NCUA Budget Transparency Act/ GAO Study of NCUA budgeting practices; H.R. 1188: Credit Union Small Business Jobs Creation Act/ raising MBL cap; H.R. 1195: Bureau of Consumer Financial Protection Advisory Boards Act; H.R. 1210: Portfolio Lending and Mortgage Access Act; H.R. 2473: Preserving Capital Access and Mortgage Liquidity Act of 2015; H.R. 2896: the TAILOR Act of 2015; S. 754: Cyber Security Information Sharing Act; NAFCUs Five Point Plan for Regulatory Relief (capital reforms for credit unions; field of membership improvements for credit unions; reduced consumer financial protection bureaus on credit unions; operational improvements for credit unions; 21st century data security standards); Regulatory relief for credit unions; S. 961: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; NCUAs efforts to allow credit unions to better serve rural areas; H.R. 1259: Helping Expand Lending Practices in Rural Communities Act; H.R. 1261: Bureau of Consumer Financial Protection Accountability Act/ Subjects CFPB to Congressional appropriations process; S. 774: Financial Institutions Examination Fairness and Reform Act; S. 871: HELP Rural Communities Act of 2015/ CFPB Rural Definition; H.R. 685: Mortgage Choice Act of 2015/ Points and Fees; H.R. 1408: Mortgage Servicing Asset Capital Requirements Act; H.R. 1422: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; H.R. 1529: Community Institution Mortgage Relief Act of 2015; H.R. 1941: Financial Institutions Examination Fairness and Reform Act; Regulatory Burdens; Qualified Mortgage Rule; S. 1484: Financial Regulatory Improvement Act; S. 2028: A bill to amend the Federal Credit Union Act, to advance the ability of credit unions to promote small business growth and economic development opportunities, and for other purposes; H.R. 3738: the Office of Financial Research Accountability Act of 2015; H.R. 3557: the FSOC Transparency and Accountability Act; H.R. 1660: the Federal Savings Association Charter Flexibility Act; Improve the federal charter of credit unions through the FCU Act; H.R. 989: Capital Access for Small Businesses and Jobs Act/ Supplemental Capital; H.R. 1133: To exclude extensions of credit made to veterans from the definition of a member business loan under the Federal Credit Union Act; NCUA proposed rulemaking on a federal insured credit unions member business lending; NCUAs exam scheduling policy; NAFCUs Top Ten Regulations for Eliminate of Amend (improve process for credit unions seeking changes to their field of membership; provide more meaningful exemptions for small institutions; expand credit union investment authority; allowing more transfers per month from savings accounts per Federal Reserve Regulation D; flexibility for credit unions making member business loans; NCUAs member business lending rule: update requirement to disclose account numbers to protect privacy of members; update advertising requirements for loan products and share accounts; seek improvements to the NCUA Central Liquidity Facility; obtain flexibility for federal credit unions to determine their choice of law; update simplify and make improvements to regulations governing check processing funds); S. 423: Privacy Notice Modernization Act of 2015; H.R. 22: the Surface Transportation Reauthorization and Reform Act of 2015; NCUAs proposed Field of Membership Amendments; H.R. 2995: Financial Services and General Government Appropriations Act; Require the CFPB to conduct a fair, comprehensive study before adopting a rule that would restrict arbitration and open the door to abusive class actions; NCUA third party vendor authority; CFPB request for approval under the Paperwork Reduction Act to conduct a national web-based survey relative to overdraft protection services; CFPB consumer complaint narrative database; CFPB and the student loan servicing market; CFPB integration of the Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) disclosures, consider good faith efforts to comply with TRID; financial regulators must level the playing field and promulgate rules that require non-traditional market lenders to meet basic consumer protection requirements such as those of TILA, underwriting standards for loans, and applicable state usury laws; FSOC should facilitate regulatory coordination among its member regulators; preserve the credit union tax exemption; regulatory relief including CFPB using their exemption authority more; Housing Finance Reform - it is vital that credit unions continue to have unfettered access to the secondary mortgage market and any reforms should have emphasis on fair pricing that reflects loan quality rather than quantity; Department of Labors proposed changes to the Fair Labor Standards Act for certain full-time salaried works to be eligible for overtime protections; Federal Communication Commission clarification for free end user calls made by financial institutions; Federal Communication Commission clarification regarding clarifications to the interpretations of the Telephone Consumer Protection Act; H.R. 1155: the Searching for and Cutting Regulations that are unnecessarily Burdensome (SCRUB) Act; prepaid cards - CFPB efforts to ensure that consumers using prepaid products are sufficiently informed and protected - they should find appropriate balance between adequate consumer protection and allowing consumers access to products they demand; compliance burdens related to CFPB amendments to Regulation C, HMDA; Small Business Administration SBA 7(a) business loan program; H.R. 2499: Veterans Entrepreneurship Act of 2015; FY 2016 Financial Services and General Government Appropriations bill; H.R. 427: Regulations for the Executive in Need of Scrutiny Act of 2015; Agency use of regulatory guidance; Protect responsible overdraft services; Changes to requirements under the Home Mortgage Disclosure Act; H.R. 957: Bureau of Consumer Financial Protection Inspector General Reform Act; Reform of Fannie Mae and Freddie Mac; Credit risk-guarantee fees; Military Lending Act; H.R. 1735: National Defense Authorization Act for Fiscal Year 2016; Cost-benefit analysis at federal regulatory agencies; Regulatory coordination; Regulations related to remittance transfers; Legal opinion letters at the CFPB; H.R. 9: Innovation Act; H.R. 185: Regulatory Accountability Act of 2015; H.R. 527: Small Business Regulatory Flexibility Improvements Act of 2015; H.R. 650: Preserving Access to Manufactured Housing Act; H.R. 766: Financial Institution Customer Protection Act/ Ending Operation Choke Point; H.R. 1262: Consumer Right to Financial Privacy Act of 2015; H.R. 1263: Consumer Financial Protection Safety and Soundness Improvement Act/ Changes veto authority of the Financial Stability Oversight Council; H.R. 1265: Bureau Advisory Commission Transparency Act/ Making credit union advisory council meetings public; H.R. 1266: Financial Product Safety Commission Act/ Replacing CFPB Director with Commission; H.R. 1309: Systemic Risk Designation Improvement Act of 2015; S. 881: Comprehensive Regulatory Review Act of 2015; S. 924: To require public hearings on NCUA's budget; S. 1137: PATENT Act; S. 1440: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; Ensure an Effective Payments system; Fairness under FCC ruling on autodialing and FCC oversight; modernize online lending laws and regulations; give NCUA greater flexibility with credit union lending including the ability to establish longer maturities for certain loans; preventing g-fees charged by Fannie and Freddie from being used as funding offset; NCUA 18-month Exam Cycle; Military Lending Act Database; Credit Losses Accounting Standard; FASB Accounting Standards; CFPBs expansion of data collection under Reg C, Privacy protections for data collected by CFPB; NIST notice and request for information on views on the Framework for Improving Critical Infrastructure Cybersecurity; Comments on Notice of proposed rulemaking regarding field of membership and chartering; CBSA population limit, combined statistical area, well defined local communities, rural population limits, multiple common bond charters, underserved areas, TIP charters; CFPB information collection on compliance costs and other effects of regulation; Duty to serve underserved markets; interchange rates as related to the Durbin Amendment to Dodd-Frank; Federal Reserves EGRPRA review process; FHFAs principal reduction consideration; FFIEC Cybersecurity Assessment Tool; Department of Labor Overtime Rule; Department of Labor Fiduciary Rule.
2016 · first_quarter · Banking
Consumer Financial Protection Bureaus (CFPB) Notice and Request for Comment on Web-Based Quantitative Testing Point of Sale/ATM (POS/ATM) Overdraft Disclosure Forms; Comments responding to request for information on the FHFAs proposed collection of information relating to the NSEMB; Comments on Regulatory Impact Assessment and Initial Regulatory Flexibility Analysis, RIN 1506-AB25; Concerns with CFPB future payday lending rulemakings; payday lending as related to the CFPBs Outline of Proposals Under Consideration; H.R. 3192: Homebuyers Assistance Act; H.R. 2769: Risk-Based Capital Study Act; National Credit Union Administrations (NCUA) risk-based capital proposal; H.R. 2205: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; NCUA budget transparency; H.R. 1176: NCUA Budget Transparency Act/ GAO Study of NCUA budgeting practices; H.R. 1188: Credit Union Small Business Jobs Creation Act/ raising MBL cap; H.R. 1195: Bureau of Consumer Financial Protection Advisory Boards Act; H.R. 1210: Portfolio Lending and Mortgage Access Act; H.R. 2473: Preserving Capital Access and Mortgage Liquidity Act of 2015; H.R. 2896: the TAILOR Act of 2015; S. 754: Cyber Security Information Sharing Act; NAFCUs Five Point Plan for Regulatory Relief (capital reforms for credit unions; field of membership improvements for credit unions; reduced consumer financial protection bureaus on credit unions; operational improvements for credit unions; 21st century data security standards); Regulatory relief for credit unions; S. 961: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; NCUAs efforts to allow credit unions to better serve rural areas; H.R. 1259: Helping Expand Lending Practices in Rural Communities Act; H.R. 1261: Bureau of Consumer Financial Protection Accountability Act/ Subjects CFPB to Congressional appropriations process; S. 774: Financial Institutions Examination Fairness and Reform Act; S. 871: HELP Rural Communities Act of 2015/ CFPB Rural Definition; H.R. 685: Mortgage Choice Act of 2015/ Points and Fees; H.R. 1408: Mortgage Servicing Asset Capital Requirements Act; H.R. 1422: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; H.R. 1529: Community Institution Mortgage Relief Act of 2015; H.R. 1941: Financial Institutions Examination Fairness and Reform Act; Regulatory Burdens; Qualified Mortgage Rule; S. 1484: Financial Regulatory Improvement Act; S. 2028: A bill to amend the Federal Credit Union Act, to advance the ability of credit unions to promote small business growth and economic development opportunities, and for other purposes; H.R. 3738: the Office of Financial Research Accountability Act of 2015; H.R. 3557: the FSOC Transparency and Accountability Act; H.R. 1660: the Federal Savings Association Charter Flexibility Act; Improve the federal charter of credit unions through the FCU Act; H.R. 989: Capital Access for Small Businesses and Jobs Act/ Supplemental Capital; H.R. 1133: To exclude extensions of credit made to veterans from the definition of a member business loan under the Federal Credit Union Act; NCUA proposed rulemaking on a federal insured credit unions member business lending; NCUAs exam scheduling policy; NAFCUs Top Ten Regulations for Eliminate of Amend (improve process for credit unions seeking changes to their field of membership; provide more meaningful exemptions for small institutions; expand credit union investment authority; allowing more transfers per month from savings accounts per Federal Reserve Regulation D; flexibility for credit unions making member business loans; NCUAs member business lending rule: update requirement to disclose account numbers to protect privacy of members; update advertising requirements for loan products and share accounts; seek improvements to the NCUA Central Liquidity Facility; obtain flexibility for federal credit unions to determine their choice of law; update simplify and make improvements to regulations governing check processing funds); S. 423: Privacy Notice Modernization Act of 2015; H.R. 22: the Surface Transportation Reauthorization and Reform Act of 2015; NCUAs proposed Field of Membership Amendments; H.R. 2995: Financial Services and General Government Appropriations Act; Require the CFPB to conduct a fair, comprehensive study before adopting a rule that would restrict arbitration and open the door to abusive class actions; NCUA third party vendor authority; CFPB request for approval under the Paperwork Reduction Act to conduct a national web-based survey relative to overdraft protection services; CFPB consumer complaint narrative database; CFPB and the student loan servicing market; CFPB integration of the Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) disclosures, consider good faith efforts to comply with TRID; financial regulators must level the playing field and promulgate rules that require non-traditional market lenders to meet basic consumer protection requirements such as those of TILA, underwriting standards for loans, and applicable state usury laws; FSOC should facilitate regulatory coordination among its member regulators; preserve the credit union tax exemption; regulatory relief including CFPB using their exemption authority more; Housing Finance Reform - it is vital that credit unions continue to have unfettered access to the secondary mortgage market and any reforms should have emphasis on fair pricing that reflects loan quality rather than quantity; Department of Labors proposed changes to the Fair Labor Standards Act for certain full-time salaried works to be eligible for overtime protections; Federal Communication Commission clarification for free end user calls made by financial institutions; Federal Communication Commission clarification regarding clarifications to the interpretations of the Telephone Consumer Protection Act; H.R. 1155: the Searching for and Cutting Regulations that are unnecessarily Burdensome (SCRUB) Act; prepaid cards - CFPB efforts to ensure that consumers using prepaid products are sufficiently informed and protected - they should find appropriate balance between adequate consumer protection and allowing consumers access to products they demand; compliance burdens related to CFPB amendments to Regulation C, HMDA; Small Business Administration SBA 7(a) business loan program; H.R. 2499: Veterans Entrepreneurship Act of 2015; FY 2016 Financial Services and General Government Appropriations bill; H.R. 427: Regulations for the Executive in Need of Scrutiny Act of 2015; Agency use of regulatory guidance; Protect responsible overdraft services; Changes to requirements under the Home Mortgage Disclosure Act; H.R. 957: Bureau of Consumer Financial Protection Inspector General Reform Act; Reform of Fannie Mae and Freddie Mac; Credit risk-guarantee fees; Military Lending Act; H.R. 1735: National Defense Authorization Act for Fiscal Year 2016; Cost-benefit analysis at federal regulatory agencies; Regulatory coordination; Regulations related to remittance transfers; Legal opinion letters at the CFPB; H.R. 9: Innovation Act; H.R. 185: Regulatory Accountability Act of 2015; H.R. 527: Small Business Regulatory Flexibility Improvements Act of 2015; H.R. 650: Preserving Access to Manufactured Housing Act; H.R. 766: Financial Institution Customer Protection Act/ Ending Operation Choke Point; H.R. 1262: Consumer Right to Financial Privacy Act of 2015; H.R. 1263: Consumer Financial Protection Safety and Soundness Improvement Act/ Changes veto authority of the Financial Stability Oversight Council; H.R. 1265: Bureau Advisory Commission Transparency Act/ Making credit union advisory council meetings public; H.R. 1266: Financial Product Safety Commission Act/ Replacing CFPB Director with Commission; H.R. 1309: Systemic Risk Designation Improvement Act of 2015; S. 881: Comprehensive Regulatory Review Act of 2015; S. 924: To require public hearings on NCUA's budget; S. 1137: PATENT Act; S. 1440: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; Ensure an Effective Payments system; Fairness under FCC ruling on autodialing and FCC oversight; modernize online lending laws and regulations; give NCUA greater flexibility with credit union lending including the ability to establish longer maturities for certain loans; preventing g-fees charged by Fannie and Freddie from being used as funding offset; NCUA 18-month Exam Cycle; Military Lending Act Database; Credit Losses Accounting Standard; FASB Accounting Standards; CFPBs expansion of data collection under Reg C, Privacy protections for data collected by CFPB; NIST notice and request for information on views on the Framework for Improving Critical Infrastructure Cybersecurity; Comments on Notice of proposed rulemaking regarding field of membership and chartering; CBSA population limit, combined statistical area, well defined local communities, rural population limits, multiple common bond charters, underserved areas, TIP charters; CFPB information collection on compliance costs and other effects of regulation; Duty to serve underserved markets; interchange rates as related to the Durbin Amendment to Dodd-Frank; Federal Reserves EGRPRA review process; FHFAs principal reduction consideration; FFIEC Cybersecurity Assessment Tool; Department of Labor Overtime Rule; Department of Labor Fiduciary Rule.
2016 · first_quarter · Banking
Issues related to credit union operations Issues related to credit union field of membership Issues related to credit union service organizations Issues related to vacancies on the National Credit Union Administration (NCUA) Board Issues related to NCUAs low income designation regulations Issues related to NCUA examination procedures Issues related to NCUAs regulation regarding its regulatory flexibility program Issues related to NCUAs proposed rule regarding emergency liquidity Issues related to NCUAs rulemaking process Issues related to material loss reports of the NCUA Office of Inspector General Issues related to the authority of the CFPB to exempt credit unions from its rulemaking Issues related to the CFPB proposal related to remittances and international wire transfers Issues related to the proposed CFPB form on RESPA/TILA Issues related to CFPBs Leadership Structure and Installing a Board Rather than Director Issues related to funding the CFPB through the Appropriations Process Issues related to increasing the CFPB Examination Threshold Issues related to conducting a cost-benefit analysis of all CFPB Proposals Issues related to codifying the CFPBs Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to standardizing the definition of mortgage originator Issues related to overdraft protection and check ordering practices Issues related to mortgage servicing Issues related to mortgage loan originator compensation and qualifications Issues related to high-cost mortgage loans (HOEPA) Issues related to the CFPBs proposed rule regarding qualified mortgage / ability to repay Issues related to reverse mortgages Issues related to the Financial Accounting Standards Board (FASB) Issues related to mark-to-market accounting Issues related to private equity standards Issues related to the implementation of the Unlawful Internet Gambling Prohibition Act Issues related to data and cyber security Issues related to mobile banking and mobile payments Issues related to the oversight of the Federal Housing Administration Issues related to USDA Rural Development Loan program Issues related to identity theft and fraud reduction Issues related to student lending Issues related to the Federal Home Loan Bank System Issues related to short term lending products and advance deposit products Issues related to patent reform Issues related to Federal Credit Union bylaws Issues relating to home-based credit unions Issues related to NCUAs risk-based capital proposal Issues related to NCUAs proposed rule on securitization Issues related to NCUAs regulatory review process Issues related to credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union by-laws Issues related to credit unions incidental powers Issues related to credit unions ability to offer prepaid cards Issues related to Ginnie Mae capital Issues related to credit union service to marijuana businesses Issues related to financial literacy Issues related to the Department of Justices investigation entitled, Operation Choke Point Issues related to membership eligibility in the Federal Home Loan Bank System. Issues related to the Department of Defense proposal regarding Credit Extending to Service Members under MLA Issues related to the Economic Growth and Regulatory Paperwork Reduction Act process Issues related to indirect auto lending Issues related to fixed assets Issues related to merchant data breaches Issues related to the payments system Issues related to FHFA proposed rules and FHLB eligibility for credit unions Issues related to Federal Reserve Regulatory D Issues related to 1-4 Family Non-Owner Occupied Residential Loan Treatment as Residential Rather than Business Loans Issues related to the use of Eminent Domain to Seize Performing Mortgage Loans Issues related to Housing Finance Reform Issues related to the implementation of the remittances provisions in the Dodd-Frank Act Issues related to NCUAs proposal rule on Member Business Lending Issues related to NCUAs proposed rule on Interest on Lawyer Trust Accounts (IOLTA) Issues related to credit union service to unbanked and underbanked consumers Issues related to the United States Postal Service Office of Inspector General report related to role of the postal service in financial services Issues related to the Feds implementation of same-day ACH Issues related to the regulation of corporate credit unions Issues related to the CFPBs proposed regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the payday, vehicle title, and similar lending Issues related to the CFPBs consumer complaint database Issues related to NCUAs Fixed Assets rule Issues related to NCUAs definition of small entity Issues related to NCUA's Proposed Rule on Member Business Lending Issues related to the Department of Labor's Proposed Rule on the Definition of Fiduciary Issues related to the Telephone Consumer Protection Act Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements Issues related to the Department of Labor's Proposed Overtime Eligibility rule Issues related to credit union conversions Issues related to the CFPB's proposal on arbitration Issues related to secure payments H.R. 9, the Innovation Act, all provisions H.R. 22, the FAST Act, Title LXXV, provisions related to privacy notice requirements; Title LXXXII, provisions related to the eligibility of privately insured credit unions to join a Federal Home Loan Bank; Title LXXXIX, provisions related to the designation of rural areas by the Consumer Financial Protection Bureau H.R. 185, Regulatory Accountability Act of 2015 H.R. 299, the Capital Access for Small Community Financial Institutions Act of 2015, all provisions H.R. 527, the Small Business Regulatory Flexibility Improvements Act of 2015 H.R. 601, the Eliminate Privacy Notice Confusion Act, all provisions H.R. 650, Preserving Access to Manufactured Housing Act, all provision H.R. 685, the Mortgage Choice Act, all provisions H.R. 766, Financial Institution Consumer Protection Act, all provisions H.R. 957, the Bureau of Consumer Financial Protection Inspector General Reform Act, all provisions H.R. 989, the Capital Access for Small Businesses Jobs Creation Act, all provisions H.R. 1090, Retail Investor Protection Act, all provisions H.R. 1176, the NCUA Budget Transparency Act, all provisions H.R. 1188, the Credit Union Small Business Jobs Creation Act, all provisions H.R. 1195, the Bureau of Consumer Financial Protection Advisory Boards Act, all provisions H.R. 1210, the Portfolio Lending and Mortgage Access Act, H.R. 1233, the Community Lending Enhancement and Regulatory Relief Act of 2015 H.R. 1259, the Helping Expand Lending Practices in Rural Communities Act, all provisions H.R. 1263, Consumer Financial Protection Safety and Soundness Improvement Act of 2015 H.R. 1265, the Bureau Advisory Commission Transparency Act, all provision H.R. 1266, the Financial Products Safety Commission Act of 2015 H.R. 1408, requiring a study of the capital requirements for mortgage servicing assets H.R. 1422, the Credit Union Residential Loan Parity Act H.R. 1480, the SAFE Confidentiality and Privilege Enhancement Act H.R. 1523, Community Bank Access to Capital Act of 2015 H.R. 1529, the Community Institution Mortgage Relief Act Discussion Draft, Data Security and Breach Notification Act of 2015 H.R. 1660, the Federal Savings Association Charter Flexibility Act, all provisions H.R. 1941, the Financial Institution Examination Fairness and Reform Act H.R. 2205, the Data Security Act H.R. 2213, to provide for a temporary safe harbor from the enforcement of integrated disclosure requirements for mortgage loan transactions under the Real Estate Settlement Procedures Act of 1974 and the Truth in Lending Act, and for other purposes. H.R. 2287, the National Credit Union Administration Budget Transparency Act H.R. 2473, the Preserving Capital Access and Mortgage Liquidity Act H.R. 2769, the Risk-Based Capital Study Act, all provisions H.R. 2896, the TAILOR Act H.R. 3192, the Homebuyer Assistance Act, all provisions H.R. 4893, the Risk Management and Homeowner Stability Act, all provisions S. 423, the Privacy Notice Modernization Act, all provisions S. 482, the Consumer Financial Protection Bureau Examination Reporting Threshold Act of 2015, all provisions S. 774 Financial Institutions Examination Fairness and Reform Act, all provisions S. 871, the Helping Expand Lending Practices in (HELP) Rural Communities Act S. 924, the National Credit Union Administration Budget Transparency Act S. 961, the Data Security Act S. 1367, a bill to amend the Federal Home Loan Bank Act with respect to membership eligibility of certain institutions S. 1440, the Credit Union Residential Loan Parity Act S. 1484, the Financial Regulatory Improvement Act, Title I S. 2216, the Senior$afe Act, all provisions The Heck-Stivers Amendment to H.R. 1735, the National Defense Authorization Act, related to the Department of Defenses MLA Database
2016 · first_quarter · Banking
H.R. 989, supplemental capital. H.R. 1188 member business lending. H.R. 1133 veterans exemption to member business lending cap. H.R. 299 privately insured credit unions. H.R. 601 privacy notifications.H.R. 1422 residential parity. H.R. 2679, risk based capital stop and study act. S. 1484, regulatory relief. S.2028, member business lending. S. 1440, residential parity. S. 961, data security. Merchant data breaches as they apply to financial institutions. EMV chip-card conversions. National Credit Union Administration and Consumer Financial Protection Bureau regulatory issues. Proposed rules on Field of Membership and Member Business Lending. Credit union examinations. Risk-based capital. Truth in lending disclosures (TRID). HMDA Home Mortgage Disclosure Act. Community lender exemption authority to Dodd-Frank Wall Street Reform and Consumer Protection Act.
Client expense: $110,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), SENATE
2015 · fourth_quarter · Financial Institutions/Investments/Securities
Consumer Financial Protection Bureaus (CFPB) Notice and Request for Comment on Web-Based Quantitative Testing Point of Sale/ATM (POS/ATM) Overdraft Disclosure Forms; Concerns with CFPB future payday lending rulemakings; payday lending as related to the CFPBs Outline of Proposals Under Consideration; H.R. 601: the Eliminate Privacy Notice Confusion Act; H.R. 3192: Homebuyers Assistance Act; H.R. 2769: Risk-Based Capital Study Act; National Credit Union Administrations (NCUA) risk-based capital proposal; H.R. 2205: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; NCUA budget transparency; H.R. 1176: NCUA Budget Transparency Act/ GAO Study of NCUA budgeting practices; H.R. 1188: Credit Union Small Business Jobs Creation Act/ raising MBL cap; H.R. 1195: Bureau of Consumer Financial Protection Advisory Boards Act; H.R. 1210: Portfolio Lending and Mortgage Access Act; H.R. 2473: Preserving Capital Access and Mortgage Liquidity Act of 2015; H.R. 2896: the TAILOR Act of 2015; S. 754: Cyber Security Information Sharing Act; NAFCUs Five Point Plan for Regulatory Relief (capital reforms for credit unions; field of membership improvements for credit unions; reduced consumer financial protection bureaus on credit unions; operational improvements for credit unions; 21st century data security standards); Regulatory relief for credit unions; S. 961: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; NCUAs efforts to allow credit unions to better serve rural areas; H.R. 1259: Helping Expand Lending Practices in Rural Communities Act;H.R. 1261: Bureau of Consumer Financial Protection Accountability Act/ Subjects CFPB to Congressional appropriations process; S. 774: Financial Institutions Examination Fairness and Reform Act; S. 871: HELP Rural Communities Act of 2015/ CFPB Rural Definition; H.R. 685: Mortgage Choice Act of 2015/ Points and Fees; H.R. 1408: Mortgage Servicing Asset Capital Requirements Act; H.R. 1422: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; H.R. 1529: Community Institution Mortgage Relief Act of 2015; H.R. 1941: Financial Institutions Examination Fairness and Reform Act; Regulatory Burdens; Qualified Mortgage Rule; S. 1484: Financial Regulatory Improvement Act; S. 2028: A bill to amend the Federal Credit Union Act, to advance the ability of credit unions to promote small business growth and economic development opportunities, and for other purposes; H.R. 3738: the Office of Financial Research Accountability Act of 2015; H.R. 3557: the FSOC Transparency and Accountability Act; H.R. 1660: the Federal Savings Association Charter Flexibility Act; Improve the federal charter of credit unions through the FCU Act; H.R. 989: Capital Access for Small Businesses and Jobs Act/ Supplemental Capital; H.R. 1133: To exclude extensions of credit made to veterans from the definition of a member business loan under the Federal Credit Union Act; NCUA proposed rulemaking on a federal insured credit unions member business lending; NCUAs exam scheduling policy; NAFCUs Top Ten Regulations for Eliminate of Amend (improve process for credit unions seeking changes to their field of membership; provide more meaningful exemptions for small institutions; expand credit union investment authority; allowing more transfers per month from savings accounts per Federal Reserve Regulation D; flexibility for credit unions making member business loans; update requirement to disclose account numbers to protect privacy of members; update advertising requirements for loan products and share accounts; seek improvements to the NCUA Central Liquidity Facility; obtain flexibility for federal credit unions to determine their choice of law; update simplify and make improvements to regulations governing check processing funds); S. 423: Privacy Notice Modernization Act of 2015; H.R. 22: the Surface Transportation Reauthorization and Reform Act of 2015; NCUAs proposed Field of Membership Amendments; H.R. 2995: Financial Services and General Government Appropriations Act; Require the CFPB to conduct a fair, comprehensive study before adopting a rule that would restrict arbitration and open the door to abusive class actions; NCUA third party vendor authority; CFPB request for approval under the Paperwork Reduction Act to conduct a national web-based survey relative to overdraft protection services; CFPB consumer complaint narrative database; CFPB and the student loan servicing market; CFPB integration of the Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) disclosures; financial regulators must level the playing field and promulgate rules that require non-traditional market lenders to meet basic consumer protection requirements such as those of TILA, underwriting standards for loans, and applicable state usury laws; FSOC should facilitate regulatory coordination among its member regulators; preserve the credit union tax exemption; regulatory relief including CFPB using their exemption authority more; Housing Finance Reform - it is vital that credit unions continue to have unfettered access to the secondary mortgage market and any reforms should have emphasis on fair pricing that reflects loan quality rather than quantity; Department of Labors proposed changes to the Fair Labor Standards Act for certain full-time salaried works to be eligible for overtime protections; Federal Communication Commission clarification for free end user calls made by financial institutions; Federal Communication Commission clarification regarding clarifications to the interpretations of the Telephone Consumer Protection Act; H.R. 1155: the Searching for and Cutting Regulations that are unnecessarily Burdensome (SCRUB) Act; prepaid cards - CFPB efforts to ensure that consumers using prepaid products are sufficiently informed and protected - they should find appropriate balance between adequate consumer protection and allowing consumers access to products they demand; compliance burdens related to CFPB amendments to Regulation C, HMDA; Small Business Administration SBA 7(a) business loan program; H.R. 2499: Veterans Entrepreneurship Act of 2015; FY 2016 Financial Services and General Government Appropriations bill; H.R. 427: Regulations for the Executive in Need of Scrutiny Act of 2015; Agency use of regulatory guidance; Overdraft services; Changes to requirements under the Home Mortgage Disclosure Act; H.R. 957: Bureau of Consumer Financial Protection Inspector General Reform Act; Reform of Fannie Mae and Freddie Mac; Credit risk-guarantee fees; Military Lending Act; H.R. 1735: National Defense Authorization Act for Fiscal Year 2016; Cost-benefit analysis at federal regulatory agencies; Regulatory coordination; Regulations related to remittance transfers; Legal opinion letters at the CFPB; H.R. 9: Innovation Act; H.R. 185: Regulatory Accountability Act of 2015; H.R. 527: Small Business Regulatory Flexibility Improvements Act of 2015; H.R. 650: Preserving Access to Manufactured Housing Act; H.R. 766: Financial Institution Customer Protection Act/ Ending Operation Choke Point; H.R. 1262: Consumer Right to Financial Privacy Act of 2015; H.R. 1263: Consumer Financial Protection Safety and Soundness Improvement Act/ Changes veto authority of the Financial Stability Oversight Council; H.R. 1265: Bureau Advisory Commission Transparency Act/ Making credit union advisory council meetings public; H.R. 1266: Financial Product Safety Commission Act/ Replacing CFPB Director with Commission; H.R. 1309: Systemic Risk Designation Improvement Act of 2015; S. 881: Comprehensive Regulatory Review Act of 2015; S. 924: To require public hearings on NCUA's budget; S. 1137: PATENT Act; S. 1440: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption.
2015 · fourth_quarter · Banking
Consumer Financial Protection Bureaus (CFPB) Notice and Request for Comment on Web-Based Quantitative Testing Point of Sale/ATM (POS/ATM) Overdraft Disclosure Forms; Concerns with CFPB future payday lending rulemakings; payday lending as related to the CFPBs Outline of Proposals Under Consideration; H.R. 601: the Eliminate Privacy Notice Confusion Act; H.R. 3192: Homebuyers Assistance Act; H.R. 2769: Risk-Based Capital Study Act; National Credit Union Administrations (NCUA) risk-based capital proposal; H.R. 2205: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; NCUA budget transparency; H.R. 1176: NCUA Budget Transparency Act/ GAO Study of NCUA budgeting practices; H.R. 1188: Credit Union Small Business Jobs Creation Act/ raising MBL cap; H.R. 1195: Bureau of Consumer Financial Protection Advisory Boards Act; H.R. 1210: Portfolio Lending and Mortgage Access Act; H.R. 2473: Preserving Capital Access and Mortgage Liquidity Act of 2015; H.R. 2896: the TAILOR Act of 2015; S. 754: Cyber Security Information Sharing Act; NAFCUs Five Point Plan for Regulatory Relief (capital reforms for credit unions; field of membership improvements for credit unions; reduced consumer financial protection bureaus on credit unions; operational improvements for credit unions; 21st century data security standards); Regulatory relief for credit unions; S. 961: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; NCUAs efforts to allow credit unions to better serve rural areas; H.R. 1259: Helping Expand Lending Practices in Rural Communities Act;H.R. 1261: Bureau of Consumer Financial Protection Accountability Act/ Subjects CFPB to Congressional appropriations process; S. 774: Financial Institutions Examination Fairness and Reform Act; S. 871: HELP Rural Communities Act of 2015/ CFPB Rural Definition; H.R. 685: Mortgage Choice Act of 2015/ Points and Fees; H.R. 1408: Mortgage Servicing Asset Capital Requirements Act; H.R. 1422: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; H.R. 1529: Community Institution Mortgage Relief Act of 2015; H.R. 1941: Financial Institutions Examination Fairness and Reform Act; Regulatory Burdens; Qualified Mortgage Rule; S. 1484: Financial Regulatory Improvement Act; S. 2028: A bill to amend the Federal Credit Union Act, to advance the ability of credit unions to promote small business growth and economic development opportunities, and for other purposes; H.R. 3738: the Office of Financial Research Accountability Act of 2015; H.R. 3557: the FSOC Transparency and Accountability Act; H.R. 1660: the Federal Savings Association Charter Flexibility Act; Improve the federal charter of credit unions through the FCU Act; H.R. 989: Capital Access for Small Businesses and Jobs Act/ Supplemental Capital; H.R. 1133: To exclude extensions of credit made to veterans from the definition of a member business loan under the Federal Credit Union Act; NCUA proposed rulemaking on a federal insured credit unions member business lending; NCUAs exam scheduling policy; NAFCUs Top Ten Regulations for Eliminate of Amend (improve process for credit unions seeking changes to their field of membership; provide more meaningful exemptions for small institutions; expand credit union investment authority; allowing more transfers per month from savings accounts per Federal Reserve Regulation D; flexibility for credit unions making member business loans; update requirement to disclose account numbers to protect privacy of members; update advertising requirements for loan products and share accounts; seek improvements to the NCUA Central Liquidity Facility; obtain flexibility for federal credit unions to determine their choice of law; update simplify and make improvements to regulations governing check processing funds); S. 423: Privacy Notice Modernization Act of 2015; H.R. 22: the Surface Transportation Reauthorization and Reform Act of 2015; NCUAs proposed Field of Membership Amendments; H.R. 2995: Financial Services and General Government Appropriations Act; Require the CFPB to conduct a fair, comprehensive study before adopting a rule that would restrict arbitration and open the door to abusive class actions; NCUA third party vendor authority; CFPB request for approval under the Paperwork Reduction Act to conduct a national web-based survey relative to overdraft protection services; CFPB consumer complaint narrative database; CFPB and the student loan servicing market; CFPB integration of the Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) disclosures; financial regulators must level the playing field and promulgate rules that require non-traditional market lenders to meet basic consumer protection requirements such as those of TILA, underwriting standards for loans, and applicable state usury laws; FSOC should facilitate regulatory coordination among its member regulators; preserve the credit union tax exemption; regulatory relief including CFPB using their exemption authority more; Housing Finance Reform - it is vital that credit unions continue to have unfettered access to the secondary mortgage market and any reforms should have emphasis on fair pricing that reflects loan quality rather than quantity; Department of Labors proposed changes to the Fair Labor Standards Act for certain full-time salaried works to be eligible for overtime protections; Federal Communication Commission clarification for free end user calls made by financial institutions; Federal Communication Commission clarification regarding clarifications to the interpretations of the Telephone Consumer Protection Act; H.R. 1155: the Searching for and Cutting Regulations that are unnecessarily Burdensome (SCRUB) Act; prepaid cards - CFPB efforts to ensure that consumers using prepaid products are sufficiently informed and protected - they should find appropriate balance between adequate consumer protection and allowing consumers access to products they demand; compliance burdens related to CFPB amendments to Regulation C, HMDA; Small Business Administration SBA 7(a) business loan program; H.R. 2499: Veterans Entrepreneurship Act of 2015; FY 2016 Financial Services and General Government Appropriations bill; H.R. 427: Regulations for the Executive in Need of Scrutiny Act of 2015; Agency use of regulatory guidance; Overdraft services; Changes to requirements under the Home Mortgage Disclosure Act; H.R. 957: Bureau of Consumer Financial Protection Inspector General Reform Act; Reform of Fannie Mae and Freddie Mac; Credit risk-guarantee fees; Military Lending Act; H.R. 1735: National Defense Authorization Act for Fiscal Year 2016; Cost-benefit analysis at federal regulatory agencies; Regulatory coordination; Regulations related to remittance transfers; Legal opinion letters at the CFPB; H.R. 9: Innovation Act; H.R. 185: Regulatory Accountability Act of 2015; H.R. 527: Small Business Regulatory Flexibility Improvements Act of 2015; H.R. 650: Preserving Access to Manufactured Housing Act; H.R. 766: Financial Institution Customer Protection Act/ Ending Operation Choke Point; H.R. 1262: Consumer Right to Financial Privacy Act of 2015; H.R. 1263: Consumer Financial Protection Safety and Soundness Improvement Act/ Changes veto authority of the Financial Stability Oversight Council; H.R. 1265: Bureau Advisory Commission Transparency Act/ Making credit union advisory council meetings public; H.R. 1266: Financial Product Safety Commission Act/ Replacing CFPB Director with Commission; H.R. 1309: Systemic Risk Designation Improvement Act of 2015; S. 881: Comprehensive Regulatory Review Act of 2015; S. 924: To require public hearings on NCUA's budget; S. 1137: PATENT Act; S. 1440: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption.
2015 · fourth_quarter · Financial Institutions/Investments/Securities
Supplemental capital issues, regulatory issues for credit unions and tax exemption status: HR185; HR 299; HR 601; HR 685; HR 957; HR 989; HR 1090 HR 1133; HR 1176; HR 1188; HR 1195; HR 1233; HR 1266; HR 1408; HR 1422; HR 1480; HR 1491; HR 1529; HR 1550; HR 1659; HR 1660; HR 1661; HR 1737; HR 1941; HR 2099; HR 2205; HR 2213; HR 2473; HR 2477; HR 2642; HR 2769; HR 3192; HR 3340; HR 3557; HR 3700; HR 3738; HR 3808; HR 3857; HR 4099; HR 4166; HR 4210; S. 423; S. 482; S. 726; S. 774; S. 924; S. 970; S. 1383; S. 1440; S. 1484; S. 1491; S. 2006; S. 2028; S. 2038; S. 2315 data security and cybersecurity; patent reform; FHLB membership rules; CFPB and FSOC reform; and GSE reform.
Client expense: Not reported · Firm income: $40,000
2015 · fourth_quarter · Banking
Issues related to credit union operations Issues related to credit union field of membership Issues related to credit union service organizations Issues related to vacancies on the National Credit Union Administration (NCUA) Board Issues related to NCUAs low income designation regulations Issues related to NCUA examination procedures Issues related to NCUAs regulation regarding its regulatory flexibility program Issues related to NCUAs proposed rule regarding emergency liquidity Issues related to NCUAs rulemaking process Issues related to material loss reports of the NCUA Office of Inspector General Issues related to the authority of the CFPB to exempt credit unions from its rulemaking Issues related to the CFPB proposal related to remittances and international wire transfers Issues related to the proposed CFPB form on RESPA/TILA Issues related to CFPBs Leadership Structure and Installing a Board Rather than Director Issues related to funding the CFPB through the Appropriations Process Issues related to increasing the CFPB Examination Threshold Issues related to conducting a cost-benefit analysis of all CFPB Proposals Issues related to codifying the CFPBs Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to standardizing the definition of mortgage originator Issues related to overdraft protection and check ordering practices Issues related to mortgage servicing Issues related to mortgage loan originator compensation and qualifications Issues related to high-cost mortgage loans (HOEPA) Issues related to the CFPBs proposed rule regarding qualified mortgage / ability to repay Issues related to reverse mortgages Issues related to the Financial Accounting Standards Board (FASB) Issues related to mark-to-market accounting Issues related to private equity standards Issues related to the implementation of the Unlawful Internet Gambling Prohibition Act Issues related to data and cyber security Issues related to mobile banking and mobile payments Issues related to the oversight of the Federal Housing Administration Issues related to USDA Rural Development Loan program Issues related to identity theft and fraud reduction Issues related to student lending Issues related to the Federal Home Loan Bank System Issues related to short term lending products and advance deposit products Issues related to patent reform Issues related to Federal Credit Union bylaws Issues relating to home-based credit unions Issues related to NCUAs risk-based capital proposal Issues related to NCUAs proposed rule on securitization Issues related to NCUAs regulatory review process Issues related to credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union by-laws Issues related to credit unions incidental powers Issues related to credit unions ability to offer prepaid cards Issues related to Ginnie Mae capital Issues related to credit union service to marijuana businesses Issues related to financial literacy Issues related to the Department of Justices investigation entitled, Operation Choke Point Issues related to membership eligibility in the Federal Home Loan Bank System. Issues related to the Department of Defense proposal regarding Credit Extending to Service Members under MLA Issues related to the Economic Growth and Regulatory Paperwork Reduction Act process Issues related to indirect auto lending Issues related to fixed assets Issues related to merchant data breaches Issues related to the payments system Issues related to FHFA proposed rules and FHLB eligibility for credit unions Issues related to Federal Reserve Regulatory D Issues related to 1-4 Family Non-Owner Occupied Residential Loan Treatment as Residential Rather than Business Loans Issues related to the use of Eminent Domain to Seize Performing Mortgage Loans Issues related to Housing Finance Reform Issues related to the implementation of the remittances provisions in the Dodd-Frank Act Issues related to NCUAs proposal rule on Member Business Lending Issues related to NCUAs proposed rule on Interest on Lawyer Trust Accounts (IOLTA) Issues related to credit union service to unbanked and underbanked consumers Issues related to the United States Postal Service Office of Inspector General report related to role of the postal service in financial services Issues related to the Feds implementation of same-day ACH Issues related to the regulation of corporate credit unions Issues related to the CFPBs proposed regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the payday, vehicle title, and similar lending Issues related to the CFPBs consumer complaint database Issues related to NCUAs Fixed Assets rule Issues related to NCUAs definition of small entity Issues related to NCUA's Proposed Rule on Member Business Lending Issues related to the Department of Labor's Proposed Rule on the Definition of Fiduciary Issues related to the Telephone Consumer Protection Act Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements Issues related to the Department of Labor's Proposed Overtime Eligibility rule H.R. 9, the Innovation Act, all provisions H.R. 22, the FAST Act, Title LXXV, provisions related to privacy notice requirements; Title LXXXII, provisions related to the eligibility of privately insured credit unions to join a Federal Home Loan Bank; Title LXXXIX, provisions related to the designation of rural areas by the Consumer Financial Protection Bureau H.R. 185, Regulatory Accountability Act of 2015 H.R. 299, the Capital Access for Small Community Financial Institutions Act of 2015, all provisions H.R. 527, the Small Business Regulatory Flexibility Improvements Act of 2015 H.R. 601, the Eliminate Privacy Notice Confusion Act, all provisions H.R. 650, Preserving Access to Manufactured Housing Act, all provision H.R. 685, the Mortgage Choice Act, all provisions H.R. 766, Financial Institution Consumer Protection Act, all provisions H.R. 957, the Bureau of Consumer Financial Protection Inspector General Reform Act, all provisions H.R. 989, the Capital Access for Small Businesses Jobs Creation Act, all provisions H.R. 1090, Retail Investor Protection Act, all provisions H.R. 1176, the NCUA Budget Transparency Act, all provisions H.R. 1188, the Credit Union Small Business Jobs Creation Act, all provisions H.R. 1195, the Bureau of Consumer Financial Protection Advisory Boards Act, all provisions H.R. 1210, the Portfolio Lending and Mortgage Access Act, H.R. 1233, the Community Lending Enhancement and Regulatory Relief Act of 2015 H.R. 1259, the Helping Expand Lending Practices in Rural Communities Act, all provisions H.R. 1263, Consumer Financial Protection Safety and Soundness Improvement Act of 2015 H.R. 1265, the Bureau Advisory Commission Transparency Act, all provision H.R. 1266, the Financial Products Safety Commission Act of 2015 H.R. 1408, requiring a study of the capital requirements for mortgage servicing assets H.R. 1422, the Credit Union Residential Loan Parity Act H.R. 1480, the SAFE Confidentiality and Privilege Enhancement Act H.R. 1523, Community Bank Access to Capital Act of 2015 H.R. 1529, the Community Institution Mortgage Relief Act Discussion Draft, Data Security and Breach Notification Act of 2015 H.R. 1660, the Federal Savings Association Charter Flexibility Act, all provisions H.R. 1941, the Financial Institution Examination Fairness and Reform Act H.R. 2205, the Data Security Act H.R. 2213, to provide for a temporary safe harbor from the enforcement of integrated disclosure requirements for mortgage loan transactions under the Real Estate Settlement Procedures Act of 1974 and the Truth in Lending Act, and for other purposes. H.R. 2287, the National Credit Union Administration Budget Transparency Act H.R. 2473, the Preserving Capital Access and Mortgage Liquidity Act H.R. 2769, the Risk-Based Capital Study Act, all provisions H.R. 2896, the TAILOR Act H.R. 3192, the Homebuyer Assistance Act, all provisions S. 423, the Privacy Notice Modernization Act, all provisions S. 482, the Consumer Financial Protection Bureau Examination Reporting Threshold Act of 2015, all provisions S. 774 Financial Institutions Examination Fairness and Reform Act, all provisions S. 871, the Helping Expand Lending Practices in (HELP) Rural Communities Act S. 924, the National Credit Union Administration Budget Transparency Act S. 961, the Data Security Act S. 1367, a bill to amend the Federal Home Loan Bank Act with respect to membership eligibility of certain institutions S. 1440, the Credit Union Residential Loan Parity Act S. 1484, the Financial Regulatory Improvement Act, Title I The Heck-Stivers Amendment to H.R. 1735, the National Defense Authorization Act, related to the Department of Defenses MLA Database
2015 · fourth_quarter · Banking
H.R. 989, supplemental capital. H.R. 1188 member business lending. H.R. 1133 veterans exemption to member business lending cap. H.R. 299 privately insured credit unions. H.R. 601 privacy notifications.H.R. 1422 residential parity. H.R. 2679, risk based capital stop and study act. S. 1484, regulatory relief. S.2028, member business lending. S. 1440, residential parity. S. 961, data security. Merchant data breaches as they apply to financial institutions. National Credit Union Administration and Consumer Financial Protection Bureau regulatory issues. Proposed rules on Field of Membership and Member Business Lending. Credit union examinations. Risk-based capital. Truth in lending disclosures (TRID).
Client expense: $110,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), SENATE
2015 · fourth_quarter · Banking
H.R. 1188 - Credit Union Small Business Jobs Creation Act - entire bill relating to increasing credit union member business lending cap; S. 2028 - Small Business Lending Enhancement Act of 2015 - same issue as above; H.R. 989 - Capital Access for Small Businesses and Jobs Act - entire bill relating to supplemental capital ratios for credit unions; H.R. 601 - Eliminate Privacy Notice Confusion Act - entire bill eliminating requirement that financial institutions privacy notices be sent on annual basis and allow such notices to be sent only when privacy policy changes; S. 423 - Privacy Notice Modernization Act of 2013 - same issues as above; S. 177 and draft House bill - Data Security and Breach Notification Act of 2015 - entire bill relating to security procedures and standards for entities maintaining personal data; 12 CFR Parts 700 - 703: Prompt Corrective Action - Risk-Based Capital - National Credit Union Administration proposed rule on risk-based capital requirements for federally insured credit unions; H.R. 1422 and S. 1440 - Credit Union Residential Loan Parity Act - reclassifies a credit union non-owner real estate loan from a business to a residential loan; H.R. 2473 - Preserving Capital Access and Mortgage Liquidity Act of 2015 - provides credit unions parity with comparable sized banks in Federal Home Loan Bank System.
Client expense: Not reported · Firm income: $30,000
2015 · third_quarter · Financial Institutions/Investments/Securities
Supplemental capital issues, regulatory issues for credit unions and tax exemption status: HR185; HR 299; HR 601; HR 685; HR 957; HR 989; HR 1090 HR 1133; HR 1176; HR 1188; HR 1195; HR 1233; HR 1266; HR 1408; HR 1422; HR 1480; HR 1491; HR 1529; HR 1550; HR 1659; HR 1660; HR 1661; HR 1737; HR 1941; HR 2099; HR 2205; HR 2213; HR 2473; HR 2477; HR 2642; HR 2769; HR 3192 S. 423; S. 482; S. 726; S. 774; S. 924; S. 970; S. 1383; S. 1440; S. 1484; S. 1491; S. 2006; S. 2028 data security and cybersecurity; patent reform; FHLB membership rules; CFPB and FSOC reform; and GSE reform.
Client expense: Not reported · Firm income: $40,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2015 · third_quarter · Financial Institutions/Investments/Securities
Consumer Financial Protection Bureaus (CFPB) request for approval under the Paperwork Reduction Act to conduct a national web-based survey relative to overdraft protection services; CFPB consumer complaint narrative database; CFPB and the student loan servicing market; CFPB integration of the Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) disclosures; U.S. Department of Education rule making on student accounts in receipt of Title IV Higher Education Act program funds; Department of Labors proposed changes to the Fair Labor Standards Act for certain full-time salaried works to be eligible for overtime protections; Federal Communication Commission clarification for free end user calls made by financial institutions; Federal Communication Commission clarification regarding clarifications to the interpretations of the Telephone Consumer Protection Act; Federal Housing Finance Agencys calculation to the Housing Price Index; Federal Reserve Boards proposed enhancements to the Federal Reserve Banks Automated Cleaning House Service; U.S. Department of Housing and Urban Development on its proposed revisions to the HUD Addendum to Uniform Residential Loan Application; U.S. Department of Housing and Urban Development proposed rule to the Federal Housing Administrations single-family procedures for filing and calculating claims under the insurance program; National Credit Union Administrations (NCUA) request for comment on the review of its regulations pursuant to the Economic Growth and Regulatory Paperwork Reduction Act of 1996; Federal Financial Institutions Examination Council Cybersecurity Assessment Tool; NCUA proposed rulemaking on a federal insured credit unions member business lending; NCUAs exam scheduling policy; NCUAs request for comment on the collection of information related to the final interagency policy statement on diversity policies and practices; NCUAs 2015 Regulatory Review; NCUAs mid-year budget review; NCUAs rules and regulations governing share insurance coverage; NCUAs risk-based capital proposal; Retention of the credit union tax exemption; Cyber security; Data security;S. 754: Cyber Security Information Sharing Act; NAFCUs Five Point Plan for Regulatory Relief (capital reforms for credit unions; field of membership improvements for credit unions; reduced consumer financial protection bureaus on credit unions; operational improvements for credit unions; 21st century data security standards); Regulatory relief for credit unions; H.R. 3038: Highway Transportation Funding Act of 2015; Funding for the Highway Transportation Funding Act of 2015; Additional mortgage reporting requirements for lenders to the Internal Revenue Service; NCUA budget transparency; NCUA third party vendor authority; Small Business Administration SBA 7(a) business loan program; H.R. 2499: Veterans Entrepreneurship Act of 2015; FY 2016 Financial Services and General Government Appropriations bill; H.R. 427: Regulations for the Executive in Need of Scrutiny Act of 2015; NAFCUs Top Ten Regulations for Eliminate of Amend (improve process for credit unions seeking changes to their field of membership; provide more meaningful exemptions for small institutions; expand credit union investment authority; allowing more transfers per month from savings accounts per Federal Reserve Regulation D; flexibility for credit unions making member business loans; update requirement to disclose account numbers to protect privacy of members; update advertising requirements for loan products and share accounts; seek improvements to the NCUA Central Liquidity Facility; obtain flexibility for federal credit unions to determine their choice of law; update simplify and make improvements to regulations governing check processing funds); S.A. 2607 to Senate cybersecurity legislation that would allow NCUA to regulate and examine service providers to credit unions; Agency use of regulatory guidance; Overdraft services; Changes to requirements under the Home Mortgage Disclosure Act; H.R. 957: Bureau of Consumer Financial Protection Inspector General Reform Act; Reform of Fannie Mae and Freddie Mac; Credit risk-guarantee fees; Military Lending Act; H.R. 1735: National Defense Authorization Act for Fiscal Year 2016; Cost-benefit analysis at federal regulatory agencies; Regulatory coordination; Regulations related to remittance transfers; Legal opinion letters at the CFPB; H.R. 9: Innovation Act; H.R. 185: Regulatory Accountability Act of 2015; H.R. 527: Small Business Regulatory Flexibility Improvements Act of 2015; H.R. 601: Eliminate Privacy Notice Confusion Act; H.R. 650: Preserving Access to Manufactured Housing Act; H.R. 685: Mortgage Choice Act of 2015/ Points and Fees;H.R. 766: Financial Institution Customer Protection Act/ Ending Operation Choke Point; H.R. 989: Capital Access for Small Businesses and Jobs Act/ Supplemental Capital; H.R. 1133: To exclude extensions of credit made to veterans from the definition of a member business loan under the Federal Credit Union Act; H.R. 1176: NCUA Budget Transparency Act/ GAO Study of NCUA budgeting practices; H.R. 1188: Credit Union Small Business Jobs Creation Act/ Lifting MBL cap; H.R. 1195: Bureau of Consumer Financial Protection Advisory Boards Act; H.R. 1210: Portfolio Lending and Mortgage Access Act; H.R. 1233: CLEARR Act of 2015; H.R. 1259: Helping Expand Lending Practices in Rural Communities Act;H.R. 1261: Bureau of Consumer Financial Protection Accountability Act/ Subjects CFPB to Congressional appropriations process; H.R. 1262: Consumer Right to Financial Privacy Act of 2015; H.R. 1263: Consumer Financial Protection Safety and Soundness Improvement Act/ Changes veto authority of the Financial Stability Oversight Council; H.R. 1265: Bureau Advisory Commission Transparency Act/ Making credit union advisory council meetings public; H.R. 1266: Financial Product Safety Commission Act/ Replacing CFPB Director with Commission; H.R. 1309: Systemic Risk Designation Improvement Act of 2015; H.R. 1408: Mortgage Servicing Asset Capital Requirements Act; H.R. 1422: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; H.R. 1529: Community Institution Mortgage Relief Act of 2015; H.R. 1941: Financial Institutions Examination Fairness and Reform Act; H.R. 2205: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; H.R. 2213: To provide for a safe harbor from the enforcement of integrated disclosure requirements for TILA/RESPA; H.R. 2287: To require public hearings on NCUAs budget; H.R. 2769: Risk-Based Capital Study Act; H.R. 3048: Community Financial Institution Exemption Act; H.R. 3192: Homebuyers Assistance Act; S. 423: Privacy Notice Modernization Act of 2015; S. 482: Consumer Financial Protection Bureau Examination and Reporting Threshold Act of 2015; S. 774: Financial Institutions Examination Fairness and Reform Act; S. 812: CLEAR Relief Act of 2015; S. 871: HELP Rural Communities Act of 2015/ CFPB Rural Definition; S. 881: Comprehensive Regulatory Review Act of 2015; S. 924: To require public hearings on NCUA's budget; S. 961: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; S. 1137: PATENT Act; S. 1440: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; S. 1484: Financial Regulatory Improvement Act; S. 2028: A bill to amend the Federal Credit Union Act, to advance the ability of credit unions to promote small business growth and economic development opportunities, and for other purposes; S. 1711: to provide a temporary safe harbor from enforcement of integrated disclosure requirements for mortgage loan transactions under TILA-RESPA; FHFA membership access proposal; H.R. 2473: Preserving Capital Access and Mortgage Liquidity Act of 2015; H.R. 2896 TAILOR Act of 2015.
2015 · third_quarter · Banking
Consumer Financial Protection Bureaus (CFPB) request for approval under the Paperwork Reduction Act to conduct a national web-based survey relative to overdraft protection services; CFPB consumer complaint narrative database; CFPB and the student loan servicing market; CFPB integration of the Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) disclosures; U.S. Department of Education rule making on student accounts in receipt of Title IV Higher Education Act program funds; Department of Labors proposed changes to the Fair Labor Standards Act for certain full-time salaried works to be eligible for overtime protections; Federal Communication Commission clarification for free end user calls made by financial institutions; Federal Communication Commission clarification regarding clarifications to the interpretations of the Telephone Consumer Protection Act; Federal Housing Finance Agencys calculation to the Housing Price Index; Federal Reserve Boards proposed enhancements to the Federal Reserve Banks Automated Cleaning House Service; U.S. Department of Housing and Urban Development on its proposed revisions to the HUD Addendum to Uniform Residential Loan Application; U.S. Department of Housing and Urban Development proposed rule to the Federal Housing Administrations single-family procedures for filing and calculating claims under the insurance program; National Credit Union Administrations (NCUA) request for comment on the review of its regulations pursuant to the Economic Growth and Regulatory Paperwork Reduction Act of 1996; Federal Financial Institutions Examination Council Cybersecurity Assessment Tool; NCUA proposed rulemaking on a federal insured credit unions member business lending; NCUAs exam scheduling policy; NCUAs request for comment on the collection of information related to the final interagency policy statement on diversity policies and practices; NCUAs 2015 Regulatory Review; NCUAs mid-year budget review; NCUAs rules and regulations governing share insurance coverage; NCUAs risk-based capital proposal; Retention of the credit union tax exemption; Cyber security; Data security;S. 754: Cyber Security Information Sharing Act; NAFCUs Five Point Plan for Regulatory Relief (capital reforms for credit unions; field of membership improvements for credit unions; reduced consumer financial protection bureaus on credit unions; operational improvements for credit unions; 21st century data security standards); Regulatory relief for credit unions; H.R. 3038: Highway Transportation Funding Act of 2015; Funding for the Highway Transportation Funding Act of 2015; Additional mortgage reporting requirements for lenders to the Internal Revenue Service; NCUA budget transparency; NCUA third party vendor authority; Small Business Administration SBA 7(a) business loan program; H.R. 2499: Veterans Entrepreneurship Act of 2015; FY 2016 Financial Services and General Government Appropriations bill; H.R. 427: Regulations for the Executive in Need of Scrutiny Act of 2015; NAFCUs Top Ten Regulations for Eliminate of Amend (improve process for credit unions seeking changes to their field of membership; provide more meaningful exemptions for small institutions; expand credit union investment authority; allowing more transfers per month from savings accounts per Federal Reserve Regulation D; flexibility for credit unions making member business loans; update requirement to disclose account numbers to protect privacy of members; update advertising requirements for loan products and share accounts; seek improvements to the NCUA Central Liquidity Facility; obtain flexibility for federal credit unions to determine their choice of law; update simplify and make improvements to regulations governing check processing funds); S.A. 2607 to Senate cybersecurity legislation that would allow NCUA to regulate and examine service providers to credit unions; Agency use of regulatory guidance; Overdraft services; Changes to requirements under the Home Mortgage Disclosure Act; H.R. 957: Bureau of Consumer Financial Protection Inspector General Reform Act; Reform of Fannie Mae and Freddie Mac; Credit risk-guarantee fees; Military Lending Act; H.R. 1735: National Defense Authorization Act for Fiscal Year 2016; Cost-benefit analysis at federal regulatory agencies; Regulatory coordination; Regulations related to remittance transfers; Legal opinion letters at the CFPB; H.R. 9: Innovation Act; H.R. 185: Regulatory Accountability Act of 2015; H.R. 527: Small Business Regulatory Flexibility Improvements Act of 2015; H.R. 601: Eliminate Privacy Notice Confusion Act; H.R. 650: Preserving Access to Manufactured Housing Act; H.R. 685: Mortgage Choice Act of 2015/ Points and Fees;H.R. 766: Financial Institution Customer Protection Act/ Ending Operation Choke Point; H.R. 989: Capital Access for Small Businesses and Jobs Act/ Supplemental Capital; H.R. 1133: To exclude extensions of credit made to veterans from the definition of a member business loan under the Federal Credit Union Act; H.R. 1176: NCUA Budget Transparency Act/ GAO Study of NCUA budgeting practices; H.R. 1188: Credit Union Small Business Jobs Creation Act/ Lifting MBL cap; H.R. 1195: Bureau of Consumer Financial Protection Advisory Boards Act; H.R. 1210: Portfolio Lending and Mortgage Access Act; H.R. 1233: CLEARR Act of 2015; H.R. 1259: Helping Expand Lending Practices in Rural Communities Act;H.R. 1261: Bureau of Consumer Financial Protection Accountability Act/ Subjects CFPB to Congressional appropriations process; H.R. 1262: Consumer Right to Financial Privacy Act of 2015; H.R. 1263: Consumer Financial Protection Safety and Soundness Improvement Act/ Changes veto authority of the Financial Stability Oversight Council; H.R. 1265: Bureau Advisory Commission Transparency Act/ Making credit union advisory council meetings public; H.R. 1266: Financial Product Safety Commission Act/ Replacing CFPB Director with Commission; H.R. 1309: Systemic Risk Designation Improvement Act of 2015; H.R. 1408: Mortgage Servicing Asset Capital Requirements Act; H.R. 1422: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; H.R. 1529: Community Institution Mortgage Relief Act of 2015; H.R. 1941: Financial Institutions Examination Fairness and Reform Act; H.R. 2205: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; H.R. 2213: To provide for a safe harbor from the enforcement of integrated disclosure requirements for TILA/RESPA; H.R. 2287: To require public hearings on NCUAs budget; H.R. 2769: Risk-Based Capital Study Act; H.R. 3048: Community Financial Institution Exemption Act; H.R. 3192: Homebuyers Assistance Act; S. 423: Privacy Notice Modernization Act of 2015; S. 482: Consumer Financial Protection Bureau Examination and Reporting Threshold Act of 2015; S. 774: Financial Institutions Examination Fairness and Reform Act; S. 812: CLEAR Relief Act of 2015; S. 871: HELP Rural Communities Act of 2015/ CFPB Rural Definition; S. 881: Comprehensive Regulatory Review Act of 2015; S. 924: To require public hearings on NCUA's budget; S. 961: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; S. 1137: PATENT Act; S. 1440: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; S. 1484: Financial Regulatory Improvement Act; S. 2028: A bill to amend the Federal Credit Union Act, to advance the ability of credit unions to promote small business growth and economic development opportunities, and for other purposes; S. 1711: to provide a temporary safe harbor from enforcement of integrated disclosure requirements for mortgage loan transactions under TILA-RESPA; FHFA membership access proposal; H.R. 2473: Preserving Capital Access and Mortgage Liquidity Act of 2015;H.R. 2896 TAILOR Act of 2015.
2015 · third_quarter · Banking
Issues related to credit union operations Issues related to credit union field of membership Issues related to credit union service organizations Issues related to vacancies on the National Credit Union Administration (NCUA) Board Issues related to NCUAs low income designation regulations Issues related to NCUA examination procedures Issues related to NCUAs regulation regarding its regulatory flexibility program Issues related to NCUAs proposed rule regarding emergency liquidity Issues related to NCUAs rulemaking process Issues related to material loss reports of the NCUA Office of Inspector General Issues related to the authority of the CFPB to exempt credit unions from its rulemaking Issues related to the CFPB proposal related to remittances and international wire transfers Issues related to the proposed CFPB form on RESPA/TILA Issues related to CFPBs Leadership Structure and Installing a Board Rather than Director Issues related to funding the CFPB through the Appropriations Process Issues related to increasing the CFPB Examination Threshold Issues related to conducting a cost-benefit analysis of all CFPB Proposals Issues related to codifying the CFPBs Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to standardizing the definition of mortgage originator Issues related to overdraft protection and check ordering practices Issues related to mortgage servicing Issues related to mortgage loan originator compensation and qualifications Issues related to high-cost mortgage loans (HOEPA) Issues related to the CFPBs proposed rule regarding qualified mortgage / ability to repay Issues related to reverse mortgages Issues related to the Financial Accounting Standards Board (FASB) Issues related to mark-to-market accounting Issues related to private equity standards Issues related to the implementation of the Unlawful Internet Gambling Prohibition Act Issues related to data and cyber security Issues related to mobile banking and mobile payments Issues related to the oversight of the Federal Housing Administration Issues related to USDA Rural Development Loan program Issues related to identity theft and fraud reduction Issues related to student lending Issues related to the Federal Home Loan Bank System Issues related to short term lending products and advance deposit products Issues related to patent reform Issues related to Federal Credit Union bylaws Issues relating to home-based credit unions Issues related to NCUAs risk-based capital proposal Issues related to NCUAs proposed rule on securitization Issues related to NCUAs regulatory review process Issues related to credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union by-laws Issues related to credit unions incidental powers Issues related to credit unions ability to offer prepaid cards Issues related to Ginnie Mae capital Issues related to credit union service to marijuana businesses Issues related to financial literacy Issues related to the Department of Justices investigation entitled, Operation Choke Point Issues related to membership eligibility in the Federal Home Loan Bank System. Issues related to the Department of Defense proposal regarding Credit Extending to Service Members under MLA Issues related to the Economic Growth and Regulatory Paperwork Reduction Act process Issues related to indirect auto lending Issues related to fixed assets Issues related to merchant data breaches Issues related to the payments system Issues related to FHFA proposed rules and FHLB eligibility for credit unions Issues related to Federal Reserve Regulatory D Issues related to 1-4 Family Non-Owner Occupied Residential Loan Treatment as Residential Rather than Business Loans Issues related to the use of Eminent Domain to Seize Performing Mortgage Loans Issues related to Housing Finance Reform Issues related to the implementation of the remittances provisions in the Dodd-Frank Act Issues related to NCUAs proposal rule on Member Business Lending Issues related to NCUAs proposed rule on Interest on Lawyer Trust Accounts (IOLTA) Issues related to credit union service to unbanked and underbanked consumers Issues related to the United States Postal Service Office of Inspector General report related to role of the postal service in financial services Issues related to the Feds implementation of same-day ACH Issues related to the regulation of corporate credit unions Issues related to the CFPBs proposed regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the payday, vehicle title, and similar lending Issues related to the CFPBs consumer complaint database Issues related to NCUAs Fixed Assets rule Issues related to NCUAs definition of small entity Issues related to NCUA's Proposed Rule on Member Business Lending Issues related to the Department of Labor's Proposed Rule on the Definition of Fiduciary H.R. 9, the Innovation Act, all provisions H.R. 185, Regulatory Accountability Act of 2015 H.R. 299, the Capital Access for Small Community Financial Institutions Act of 2015, all provisions H.R. 527, the Small Business Regulatory Flexibility Improvements Act of 2015 H.R. 601, the Eliminate Privacy Notice Confusion Act, all provisions H.R. 650, Preserving Access to Manufactured Housing Act, all provision H.R. 685, the Mortgage Choice Act, all provisions H.R. 766, Financial Institution Consumer Protection Act, all provisions H.R. 957, the Bureau of Consumer Financial Protection Inspector General Reform Act, all provisions H.R. 989, the Capital Access for Small Businesses Jobs Creation Act, all provisions H.R. 1090, Retail Investor Protection Act, all provisions H.R. 1176, the NCUA Budget Transparency Act, all provisions H.R. 1188, the Credit Union Small Business Jobs Creation Act, all provisions H.R. 1195, the Bureau of Consumer Financial Protection Advisory Boards Act, all provisions H.R. 1210, the Portfolio Lending and Mortgage Access Act, H.R. 1233, the Community Lending Enhancement and Regulatory Relief Act of 2015 H.R. 1259, the Helping Expand Lending Practices in Rural Communities Act, all provisions H.R. 1263, Consumer Financial Protection Safety and Soundness Improvement Act of 2015 H.R. 1265, the Bureau Advisory Commission Transparency Act, all provision H.R. 1266, the Financial Products Safety Commission Act of 2015 H.R. 1408, requiring a study of the capital requirements for mortgage servicing assets H.R. 1422, the Credit Union Residential Loan Parity Act H.R. 1480, the SAFE Confidentiality and Privilege Enhancement Act H.R. 1523, Community Bank Access to Capital Act of 2015 H.R. 1529, the Community Institution Mortgage Relief Act Discussion Draft, Data Security and Breach Notification Act of 2015 H.R. 1941, the Financial Institution Examination Fairness and Reform Act H.R. 2205, the Data Security Act H.R. 2213, to provide for a temporary safe harbor from the enforcement of integrated disclosure requirements for mortgage loan transactions under the Real Estate Settlement Procedures Act of 1974 and the Truth in Lending Act, and for other purposes. H.R. 2287, the National Credit Union Administration Budget Transparency Act H.R. 2473, the Preserving Capital Access and Mortgage Liquidity Act H.R. 2769, the Risk-Based Capital Study Act, all provisions H.R. 2896, the TAILOR Act H.R. 3192, the Homebuyer Assistance Act, all provisions S. 423, the Privacy Notice Modernization Act, all provisions S. 482, the Consumer Financial Protection Bureau Examination Reporting Threshold Act of 2015, all provisions S. 774 Financial Institutions Examination Fairness and Reform Act, all provisions S. 871, the Helping Expand Lending Practices in (HELP) Rural Communities Act S. 924, the National Credit Union Administration Budget Transparency Act S. 961, the Data Security Act S. 1367, a bill to amend the Federal Home Loan Bank Act with respect to membership eligibility of certain institutions S. 1440, the Credit Union Residential Loan Parity Act S. 1484, the Financial Regulatory Improvement Act, Title I The Heck-Stivers Amendment to H.R. 1735, the National Defense Authorization Act, related to the Department of Defenses MLA Database
2015 · third_quarter · Taxation/Internal Revenue Code
Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate) Credit Union Taxation and Expansion of Powers - Credit unions now indistinguishable from community banks, grown to control a significant share of the banking services market. Original business model now outdated. Credit unions strayed from founding purpose of serving individuals of modest means and with a common bond. Same financial services as community banks. Federal tax-exempt status, in exchange for serving their original mission is no longer justified. Credit unions paying their fair share of income taxes Credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L). The exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks]. The Office of Management and Budget tax expenditure analysis - tax-exemption for credit unions result in loss of tax revenues of $9.46 billion over fiscal years 2014-2018. Credit union expansion of commercial lending powers - increasing the percentage of assets cap on member business lending (MBL). Loan growth at the expense of tax-paying community banks. Fundamental altering the exclusive member-focused character of credit unions - a condition for their original tax exemption. Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts. The same Call Report filing requirements for credit unions as those imposed on community banks. Tax subsidy and level the playing field between credit unions and tax-paying community banks. Farm Credit System - Expansionist agenda of the Farm Credit System (FCS). FCS almost the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status. Tax advantages - unfair competitive advantage. Follow narrow historic mission - abolish or be subject to taxation and oversight and regulation. Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives. Support and cooperation of Farm Credit Administration (FCA) - FCS straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities. FCS significant systemic and taxpayer bail-out risks. The FCS (only GSE) in active competition with community banks. Public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks). Funding and tax benefits impact on community banks. FCS not following its narrow historical mission. Follow narrow mission or abolish System. Abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity. FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight. Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks. Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by Wall Street mega banks during the financial crisis. The different/modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a one-size-fits-all approach. Disproportionate burden of banking laws and regulations on community banks. Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks. Unlevel playing field and a significant competitive disadvantage for community banks. Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies. Excessive, redundant and costly regulations. Regulatory accountability. Community banks dedicating resources to promoting economic growth. Steady increase in regulations over many decades. Regulatory threats to community banks and their communities. The Plan for Prosperity regarding: Basel III original intent. additional capital for small holding companies - modernize the Federal Reserves Policy Statement. Securities and Exchange Commission rules. reforming mortgage lending. accountability in bank exams by providing an appeals process. bank oversight and examinations - targeting risks. annual requirement for redundant privacy notices. consumer regulation - inclusive and accountable CFPB governance. arbitrary disparate impact fair lending causes of action. viability of mutual banks with new charter options. cost-benefit analysis to justify new rules. red tape in small business lending - burdensome data collection. community bank mortgage servicing. Treasury Assistant Secretary for Community Banks. subchapter S constraints. five-year loss carryback - support for lending during economic downturns. risk targeting in the Volcker Rule. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks. Legislation - H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate) S. 1440 and H.R. 1422 - Credit Union Residential Loan Parity Act (exclude loans to non-primary residence 1-4 family dwellings from member business lending cap) (all sections) (Senate) Comment Letters - Comment Letter - National Credit Union Administration regarding proposed rulemaking for Part 723 (RIN 3133-AE37) to rewrite rules governing credit union member business lending (House and Senate) Action Alerts - National Credit Union Administration regarding proposed rulemaking to rewrite rules governing credit union member business lending
2015 · third_quarter · Financial Institutions/Investments/Securities
Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate) Too-to-Fail - Reform the financial system. The severity of a future financial crisis. The perception and reality of too-big-to-fail. Taxpayer bailouts of mega banks and financial firms. Mega bank size, complexity and interconnectedness, and candidacy for future bailouts. The number of community banks falling by more than half (currently 6,200 institutions) and now represent less than one-fifth of banking professions assets. Causes of the mortgage meltdown and financial crisis. Protection of the nation and the banking profession from a repeat of massive financial destruction. Taxpayer-funded bailouts of too-big-to-fail banks and financial firms and their numerous violations of the law, often criminal violations. Effectively management, supervision, discipline, or resolution of too-big-to-fail banks and financial firms. Mega bank multi-trillion dollars financial assistance. Community banks assistance and more than 500 failed community banks. Downsizing too-big-to-fail banks and financial firms. The fundamental American constitutional right of equal justice under the law applicability when it comes to the mega banks. The U.S. two-tiered system of justice - too-big-to-fail banks and financial firms and everyone else. The Department of Justice (DOJ) - laggard in prosecuting crimes stemming from the financial crisis. Banking regulators and the DOJ aggressively pursuing actions against community banks, their directors, and officers with board resolutions, MOUs, C&Ds, consent orders, monetary penalties, barring individuals from banking, criminal prosecution, and other actions. No mandatory Prompt Corrective Action (PCA) capital enforcement orders against any bank larger than $30 billion in assets, yet 1,400 PCAs against community banks. Evidence of a clear double standard. Opponents of downsizing the mega banks (include their paid association cheerleaders) consistently blocking meaningful reforms and obfuscating the issue of too-big-to-fail for the benefit of large members and the detriment of everyone else. Too-big-to-fail banks, directors, officers, or employees being - too-big-to-manage, too-big-to-regulate, too-big-to-fail, too-big-to-prosecute, too-big-to-jail, too-big-to-change, and clearly too-big-to-behave --- downsize. Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by Wall Street mega banks during the financial crisis. The different/modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a one-size-fits-all approach. Disproportionate burden of banking laws and regulations on community banks. Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks. Unlevel playing field and a significant competitive disadvantage for community banks. Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies. Excessive, redundant and costly regulations. Regulatory accountability. Community banks dedicating resources to promoting economic growth. Steady increase in regulations over many decades. Regulatory threats to community banks and their communities. The Plan for Prosperity regarding: Basel III original intent. additional capital for small holding companies - modernize the Federal Reserves Policy Statement. Securities and Exchange Commission rules. reforming mortgage lending. accountability in bank exams by providing an appeals process. bank oversight and examinations - targeting risks. annual requirement for redundant privacy notices. consumer regulation - inclusive and accountable CFPB governance. arbitrary disparate impact fair lending causes of action. viability of mutual banks with new charter options. cost-benefit analysis to justify new rules. red tape in small business lending - burdensome data collection. community bank mortgage servicing. Treasury Assistant Secretary for Community Banks. subchapter S constraints. five-year loss carryback - support for lending during economic downturns. risk targeting in the Volcker Rule. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks. Credit Union Taxation and Expansion of Powers - Credit unions now indistinguishable from community banks, grown to control a significant share of the banking services market. Original business model now outdated. Credit unions strayed from founding purpose of serving individuals of modest means and with a common bond. Same financial services as community banks. Federal tax-exempt status, in exchange for serving their original mission is no longer justified. Credit unions paying their fair share of income taxes Credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L). The exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks]. The Office of Management and Budget tax expenditure analysis - tax-exemption for credit unions result in loss of tax revenues of $9.46 billion over fiscal years 2014-2018. Credit union expansion of commercial lending powers - increasing the percentage of cap on member business lending (MBL). Loan growth at the expense of tax-paying community banks. Fundamental altering the exclusive member-focused character of credit unions - a condition for their original tax exemption. Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts. The same Call Report filing requirements for credit unions as those imposed on community banks. Tax subsidy and level the playing field between credit unions and tax-paying community banks. Farm Credit System - Expansionist agenda of the Farm Credit System (FCS). FCS almost the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status. Tax advantages - unfair competitive advantage. Follow narrow historic mission - abolish or be subject to taxation and oversight and regulation. Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives. Support and cooperation of Farm Credit Administration (FCA) - FCS straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities. FCS significant systemic and taxpayer bail-out risks. The FCS (only GSE) in active competition with community banks. Public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks). Funding and tax benefits impact on community banks. FCS not following its narrow historical mission. Follow narrow mission or abolish System. Abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity. FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight. Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks. Enhanced Cyber, Data and Payment Card Security - Establish a federal data security standard and notice requirement for all entities that store consumer data comparable to the Gramm-Leach-Bliley Act (GLBA) standards that apply to community banks. Shifting the liability for all costs associated with the data breach - including fraud losses and the cost of card reissuance - to the party that caused the breach. Consumer Financial Protection Bureau Mortgage Lending and Housing Finance Reform - Imprudent mortgage lending contribution to the mortgage meltdown and the financial crisis. Community banks common sense relationship lending and not participating in abusive and predatory lending practices. Community banks thriving on the strength of their reputations and incentive to make fair and reasonable loans. No need for prescriptive regulations to compel community banks to do the right thing for their customers. Curb imprudent lending practices. Not impacting responsible community bank loan products designed to meet the diverse needs of their customers, including borrowers with special needs and circumstances, first-time homebuyers, borrowers in rural and underserved areas, and low-to-moderate income borrowers. Regulators recognition of the difference between the non-traditional lending practiced by community banks and predatory lending practiced by others. Community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas should receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs). Special accommodations for small creditors, flexibility in serving the needs of customers and communities, particularly in rural areas, and the definition of underserved areas to include economically challenged areas. Reforms to the housing GSEs to include the existence of an impartial secondary market for residential mortgages, one that is financially strong and reliable, the need for some government tie to the secondary market to ensure the continued flow of credit and market liquidity during severe economic stress, no limit to full participation by community banks, and a return of private capital. Additional reforms to include community banks access to sell loans through an independent entity; no appropriation of community bank customer data for the purpose of cross selling financial services; maintain the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market; pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed; and no further consolidation of the housing finance system. Stop aggressively compelling community banks to repurchase transferred real estate mortgages for technical violations of underwriting agreements that had no bearing on the quality of the loan at the time of underwriting. Disparate Impact Fair Lending Causes of Action - Enforcement actions by the Department of Housing and Urban Development (HUD) and the Department of Justice (DOJ) - disparate impact. Additional obligation on community banks to consider such factors as race or national origin in credit decisions, which is specifically precluded by law - untenable situation Consumer Financial Protection Bureau Reform - Community banks regulatory relief to serve unique needs of their customers and not hinder new product development and innovation. Community bank flexibility to meet the unique needs of customers and community banks additional and unnecessary regulatory requirements to prevent their serving their communities. No a one-size-fits-all approach to CFPB regulations. Community banks not enduring any additional consumer regulatory burden on top of the existing regulatory burden. Single-Director governance of the CFPB versus a five-member commission. Prudential regulators participating with the CFPB in the rule-writing process. The Financial Stability Oversight Council (FSOC) power to veto CFPB rules. Broad definition of firms that grant credit being subject to the CFPB rules, and their robust supervision and examinations. Focus of any enhanced regulation of financial products on unregulated shadow financial companies. CFPBs efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products. CFPB holding mega banks and financial firms up to the existing standards for compliance with consumer laws, rules and regulations as required by community banks. Revised definitions in the Ability-to-Repay Qualified Mortgage rules of small creditor and rural areas, and expansion of the definition of underserved areas to include economically challenged areas. De Novo Community Bank Formation - Need for newly chartered (de novo) community banks. FDIC inhibiting de novo community bank formation. FDICs current position and a one-size-fits-all supervisory policy for de novos. Federal Home Loan Bank System - The Federal Home Loan Banks (FHLBs) partnership with community banks - short-term liquidity, long-term funding and other financial products and providing lendable funds for the local communities. Maintaining the regional structure, special functions and purposes of the FHLBs. The FHLB Systems health, stability and reliability for its members. FHFAs proposed (2014) revisions to FHLB membership eligibility requirements - impact on the FHLB System and its members including, but not limited to, regulatory burden, member balance sheet management, stability of the System, and continued reliability as a funding partner, future value of FHLB membership and the implications for membership decisions; and impact on housing and community development throughout the System. The proposed rule is also contrary to the will of Congress. FHLB System reliance as the sole aggregator or securitizer of residential mortgages for community banks, and the FHFAs imposition of an ongoing housing mission asset test on community financial institutions. Excessive Intervention in Monetary Policy - The sustained record-low zero interest rate policy (ZIRP) - disproportionate impact on community banks, senior citizens and discourages savings. Record-low interest rates for five years+ does not constitute temporary intervention but long-term and harmful manipulation. The limits to what Fed monetary policy can accomplish, especially given major offsetting negative effects. Legislation - H.R. 1523 - Community Bank Access to Capital Act of 2015 (enhance community bank and thrift access to capital) (all sections) (House and Senate) H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate) H.R. 2205 and S. 961 - Data Security Act of 2015 (data breach and security, notifications, safeguards, GLBA compliance procedures) (All sections) (House and Senate) H.R. 1188 - The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate) Highway Trust Fund Reauthorization - (Senate versions proposed reduction of dividends paid on Federal Reserve Bank stock as pay-for) (Senate) H.R. 1941 - Financial Institutions Examination Fairness and Reform Act (regulatory examinations standards and FFIEC Ombudsman) (all sections) (House) S. 1440 and H.R. 1422 - Credit Union Residential Loan Parity Act (exclude loans to non-primary residence 1-4 family dwellings from member business lending cap) (all sections) (Senate) State of Illinois legislation - (sharing of IDFPR state bank examination reports with the Federal Home Loan Bank of Chicago) Comment Letters - Comment Letter - CFPB, grace period for enforcement and liability in the implementation, and delay in the implementation of the TRID Comment Letter - Department of Labor, proposed increase in the salary threshold for employees who are exempt from overtime mandates of the Fair Labor Standards Act Comment Letter - National Credit Union Administration, comments on proposed rulemaking for Part 723 (RIN 3133-AE37) to rewrite rules governing credit union member business lending (House and Senate) Comment Letter - FDIC, Notice of Proposed Rulemaking and request for Comments RIN 3064-AE37 to refine the deposit insurance assessment system for small depository institutions Action Alerts - H.R. 1233 and S. 812 - Community Lending Enhancement and Regulatory (CLEAR) Relief Act of 2015 (community bank regulatory relief) (all sections) (House and Senate), and H.R. 1523 and S. 1816 - Community Bank Access to Capital (enhance community bank and thrift access to capital) (all sections) (House and Senate) Highway Trust Fund Reauthorization - (Senate versions proposed reduction of dividends paid on Federal Reserve Bank stock as pay-for) (Senate) National Credit Union Administration regarding proposed rulemaking to rewrite rules governing credit union member business lending Miscellaneous - Regarding CFPB, delay in implementation of TRID and period of restrained enforcement and liability, the definition of rural and underserved areas in the QM, regulatory burden on community banks, declining number of community banks and community bank consolidation (House) Current community bank regulatory examination environment (Senate)
2015 · third_quarter · Banking
Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate) Too-to-Fail - Reform the financial system. The severity of a future financial crisis. The perception and reality of too-big-to-fail. Taxpayer bailouts of mega banks and financial firms. Mega bank size, complexity and interconnectedness, and candidacy for future bailouts. The number of community banks falling by more than half (currently 6,200 institutions) and now represent less than one-fifth of banking professions assets. Causes of the mortgage meltdown and financial crisis. Protection of the nation and the banking profession from a repeat of massive financial destruction. Taxpayer-funded bailouts of too-big-to-fail banks and financial firms and their numerous violations of the law, often criminal violations. Effectively management, supervision, discipline, or resolution of too-big-to-fail banks and financial firms. Mega bank multi-trillion dollars financial assistance. Community banks assistance and more than 500 failed community banks. Downsizing too-big-to-fail banks and financial firms. The fundamental American constitutional right of equal justice under the law applicability when it comes to the mega banks. The U.S. two-tiered system of justice - too-big-to-fail banks and financial firms and everyone else. The Department of Justice (DOJ) - laggard in prosecuting crimes stemming from the financial crisis. Banking regulators and the DOJ aggressively pursuing actions against community banks, their directors, and officers with board resolutions, MOUs, C&Ds, consent orders, monetary penalties, barring individuals from banking, criminal prosecution, and other actions. No mandatory Prompt Corrective Action (PCA) capital enforcement orders against any bank larger than $30 billion in assets, yet 1,400 PCAs against community banks. Evidence of a clear double standard. Opponents of downsizing the mega banks (include their paid association cheerleaders) consistently blocking meaningful reforms and obfuscating the issue of too-big-to-fail for the benefit of large members and the detriment of everyone else. Too-big-to-fail banks, directors, officers, or employees being - too-big-to-manage, too-big-to-regulate, too-big-to-fail, too-big-to-prosecute, too-big-to-jail, too-big-to-change, and clearly too-big-to-behave --- downsize. Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by Wall Street mega banks during the financial crisis. The different/modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a one-size-fits-all approach. Disproportionate burden of banking laws and regulations on community banks. Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks. Unlevel playing field and a significant competitive disadvantage for community banks. Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies. Excessive, redundant and costly regulations. Regulatory accountability. Community banks dedicating resources to promoting economic growth. Steady increase in regulations over many decades. Regulatory threats to community banks and their communities. The Plan for Prosperity regarding: Basel III original intent. additional capital for small holding companies - modernize the Federal Reserves Policy Statement. Securities and Exchange Commission rules. reforming mortgage lending. accountability in bank exams by providing an appeals process. bank oversight and examinations - targeting risks. annual requirement for redundant privacy notices. consumer regulation - inclusive and accountable CFPB governance. arbitrary disparate impact fair lending causes of action. viability of mutual banks with new charter options. cost-benefit analysis to justify new rules. red tape in small business lending - burdensome data collection. community bank mortgage servicing. Treasury Assistant Secretary for Community Banks. subchapter S constraints. five-year loss carryback - support for lending during economic downturns. risk targeting in the Volcker Rule. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks. Credit Union Taxation and Expansion of Powers - Credit unions now indistinguishable from community banks, grown to control a significant share of the banking services market. Original business model now outdated. Credit unions strayed from founding purpose of serving individuals of modest means and with a common bond. Same financial services as community banks. Federal tax-exempt status, in exchange for serving their original mission is no longer justified. Credit unions paying their fair share of income taxes Credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L). The exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks]. The Office of Management and Budget tax expenditure analysis - tax-exemption for credit unions result in loss of tax revenues of $9.46 billion over fiscal years 2014-2018. Credit union expansion of commercial lending powers - increasing the percentage of cap on member business lending (MBL). Loan growth at the expense of tax-paying community banks. Fundamental altering the exclusive member-focused character of credit unions - a condition for their original tax exemption. Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts. The same Call Report filing requirements for credit unions as those imposed on community banks. Tax subsidy and level the playing field between credit unions and tax-paying community banks. Farm Credit System - Expansionist agenda of the Farm Credit System (FCS). FCS almost the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status. Tax advantages - unfair competitive advantage. Follow narrow historic mission - abolish or be subject to taxation and oversight and regulation. Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives. Support and cooperation of Farm Credit Administration (FCA) - FCS straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities. FCS significant systemic and taxpayer bail-out risks. The FCS (only GSE) in active competition with community banks. Public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks). Funding and tax benefits impact on community banks. FCS not following its narrow historical mission. Follow narrow mission or abolish System. Abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity. FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight. Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks. Enhanced Cyber, Data and Payment Card Security - Establish a federal data security standard and notice requirement for all entities that store consumer data comparable to the Gramm-Leach-Bliley Act (GLBA) standards that apply to community banks. Shifting the liability for all costs associated with the data breach - including fraud losses and the cost of card reissuance - to the party that caused the breach. Consumer Financial Protection Bureau Mortgage Lending and Housing Finance Reform - Imprudent mortgage lending contribution to the mortgage meltdown and the financial crisis. Community banks common sense relationship lending and not participating in abusive and predatory lending practices. Community banks thriving on the strength of their reputations and incentive to make fair and reasonable loans. No need for prescriptive regulations to compel community banks to do the right thing for their customers. Curb imprudent lending practices. Not impacting responsible community bank loan products designed to meet the diverse needs of their customers, including borrowers with special needs and circumstances, first-time homebuyers, borrowers in rural and underserved areas, and low-to-moderate income borrowers. Regulators recognition of the difference between the non-traditional lending practiced by community banks and predatory lending practiced by others. Community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas should receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs). Special accommodations for small creditors, flexibility in serving the needs of customers and communities, particularly in rural areas, and the definition of underserved areas to include economically challenged areas. Reforms to the housing GSEs to include the existence of an impartial secondary market for residential mortgages, one that is financially strong and reliable, the need for some government tie to the secondary market to ensure the continued flow of credit and market liquidity during severe economic stress, no limit to full participation by community banks, and a return of private capital. Additional reforms to include community banks access to sell loans through an independent entity; no appropriation of community bank customer data for the purpose of cross selling financial services; maintain the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market; pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed; and no further consolidation of the housing finance system. Stop aggressively compelling community banks to repurchase transferred real estate mortgages for technical violations of underwriting agreements that had no bearing on the quality of the loan at the time of underwriting. Disparate Impact Fair Lending Causes of Action - Enforcement actions by the Department of Housing and Urban Development (HUD) and the Department of Justice (DOJ) - disparate impact. Additional obligation on community banks to consider such factors as race or national origin in credit decisions, which is specifically precluded by law - untenable situation Consumer Financial Protection Bureau Reform - Community banks regulatory relief to serve unique needs of their customers and not hinder new product development and innovation. Community bank flexibility to meet the unique needs of customers and community banks additional and unnecessary regulatory requirements to prevent their serving their communities. No a one-size-fits-all approach to CFPB regulations. Community banks not enduring any additional consumer regulatory burden on top of the existing regulatory burden. Single-Director governance of the CFPB versus a five-member commission. Prudential regulators participating with the CFPB in the rule-writing process. The Financial Stability Oversight Council (FSOC) power to veto CFPB rules. Broad definition of firms that grant credit being subject to the CFPB rules, and their robust supervision and examinations. Focus of any enhanced regulation of financial products on unregulated shadow financial companies. CFPBs efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products. CFPB holding mega banks and financial firms up to the existing standards for compliance with consumer laws, rules and regulations as required by community banks. Revised definitions in the Ability-to-Repay Qualified Mortgage rules of small creditor and rural areas, and expansion of the definition of underserved areas to include economically challenged areas. De Novo Community Bank Formation - Need for newly chartered (de novo) community banks. FDIC inhibiting de novo community bank formation. FDICs current position and a one-size-fits-all supervisory policy for de novos. Federal Home Loan Bank System - The Federal Home Loan Banks (FHLBs) partnership with community banks - short-term liquidity, long-term funding and other financial products and providing lendable funds for the local communities. Maintaining the regional structure, special functions and purposes of the FHLBs. The FHLB Systems health, stability and reliability for its members. FHFAs proposed (2014) revisions to FHLB membership eligibility requirements - impact on the FHLB System and its members including, but not limited to, regulatory burden, member balance sheet management, stability of the System, and continued reliability as a funding partner, future value of FHLB membership and the implications for membership decisions; and impact on housing and community development throughout the System. The proposed rule is also contrary to the will of Congress. FHLB System reliance as the sole aggregator or securitizer of residential mortgages for community banks, and the FHFAs imposition of an ongoing housing mission asset test on community financial institutions. Excessive Intervention in Monetary Policy - The sustained record-low zero interest rate policy (ZIRP) - disproportionate impact on community banks, senior citizens and discourages savings. Record-low interest rates for five years+ does not constitute temporary intervention but long-term and harmful manipulation. The limits to what Fed monetary policy can accomplish, especially given major offsetting negative effects. Legislation - H.R. 1523 - Community Bank Access to Capital Act of 2015 (enhance community bank and thrift access to capital) (all sections) (House and Senate) H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate) H.R. 2205 and S. 961 - Data Security Act of 2015 (data breach and security, notifications, safeguards, GLBA compliance procedures) (All sections) (House and Senate) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate) Highway Trust Fund Reauthorization - (Senate versions proposed reduction of dividends paid on Federal Reserve Bank stock as pay-for) (Senate) H.R. 1941 - Financial Institutions Examination Fairness and Reform Act (regulatory examinations standards and FFIEC Ombudsman) (all sections) (House) S. 1440 and H.R. 1422 - Credit Union Residential Loan Parity Act (exclude loans to non-primary residence 1-4 family dwellings from member business lending cap) (all sections) (Senate) State of Illinois legislation - (sharing of IDFPR state bank examination reports with the Federal Home Loan Bank of Chicago) Comment Letters - Comment Letter - CFPB, grace period for enforcement and liability in the implementation, and delay in the implementation of the TRID Comment Letter - Department of Labor, proposed increase in the salary threshold for employees who are exempt from overtime mandates of the Fair Labor Standards Act Comment Letter - National Credit Union Administration, comments on proposed rulemaking for Part 723 (RIN 3133-AE37) to rewrite rules governing credit union member business lending (House and Senate) Comment Letter - FDIC, Notice of Proposed Rulemaking and request for Comments RIN 3064-AE37 to refine the deposit insurance assessment system for small depository institutions Action Alerts - H.R. 1233 and S. 812 - Community Lending Enhancement and Regulatory (CLEAR) Relief Act of 2015 (community bank regulatory relief) (all sections) (House and Senate), and H.R. 1523 and S. 1816 - Community Bank Access to Capital (enhance community bank and thrift access to capital) (all sections) (House and Senate) Highway Trust Fund Reauthorization - (Senate versions proposed reduction of dividends paid on Federal Reserve Bank stock as pay-for) (Senate) National Credit Union Administration regarding proposed rulemaking to rewrite rules governing credit union member business lending Miscellaneous - Regarding CFPB, delay in implementation of TRID and period of restrained enforcement and liability, the definition of rural and underserved areas in the QM, regulatory burden on community banks, declining number of community banks and community bank consolidation (House) Current community bank regulatory examination environment (Senate)
2015 · third_quarter · Banking
H.R. 1188 - Credit Union Small Business Jobs Creation Act - entire bill relating to increasing credit union member business lending cap; S. 2028 - Small Business Lending Enhancement Act of 2015 - same issue as above; H.R. 989 - Capital Access for Small Businesses and Jobs Act - entire bill relating to supplemental capital ratios for credit unions; H.R. 601 - Eliminate Privacy Notice Confusion Act - entire bill eliminating requirement that financial institutions privacy notices be sent on annual basis and allow such notices to be sent only when privacy policy changes; S. 423 - Privacy Notice Modernization Act of 2013 - same issues as above; S. 177 and draft House bill - Data Security and Breach Notification Act of 2015 - entire bill relating to security procedures and standards for entities maintaining personal data; 12 CFR Parts 700 - 703: Prompt Corrective Action - Risk-Based Capital - National Credit Union Administration proposed rule on risk-based capital requirements for federally insured credit unions; H.R. 1422 and S. 1440 - Credit Union Residential Loan Parity Act - reclassifies a credit union non-owner real estate loan from a business to a residential loan; H.R. 2473 - Preserving Capital Access and Mortgage Liquidity Act of 2015 - provides credit unions parity with comparable sized banks in Federal Home Loan Bank System.
Client expense: Not reported · Firm income: $30,000
2015 · third_quarter · Banking
H.R. 989, supplemental capital. H.R. 1188 member business lending. H.R. 1133 veterans exemption to member business lending cap. H.R. 299 privately insured credit unions. H.R. 601 privacy notifications.H.R. 1422 residential parity. H.R. 2679, risk based capital stop and study act. S. 1484, regulatory relief. S.2028, member business lending. S. 1440, residential parity. S. 961, data security. Merchant data breaches as they apply to financial institutions. National Credit Union Administration and Consumer Financial Protection Bureau regulatory issues. Credit union examinations. Risk-based capital. Truth in lending disclosures (TRID).
Client expense: $110,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2015 · second_quarter · Banking
Issues related to credit union operations Issues related to credit union field of membership Issues related to credit union service organizations Issues related to vacancies on the National Credit Union Administration (NCUA) Board Issues related to NCUAs low income designation regulations Issues related to NCUA examination procedures Issues related to NCUAs regulation regarding its regulatory flexibility program Issues related to NCUAs proposed rule regarding emergency liquidity Issues related to NCUAs rulemaking process Issues related to material loss reports of the NCUA Office of Inspector General Issues related to the authority of the CFPB to exempt credit unions from its rulemaking Issues related to the CFPB proposal related to remittances and international wire transfers Issues related to the proposed CFPB form on RESPA/TILA Issues related to CFPBs Leadership Structure and Installing a Board Rather than Director Issues related to funding the CFPB through the Appropriations Process Issues related to increasing the CFPB Examination Threshold Issues related to conducting a cost-benefit analysis of all CFPB Proposals Issues related to codifying the CFPBs Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to standardizing the definition of mortgage originator Issues related to overdraft protection and check ordering practices Issues related to mortgage servicing Issues related to mortgage loan originator compensation and qualifications Issues related to high-cost mortgage loans (HOEPA) Issues related to the CFPBs proposed rule regarding qualified mortgage / ability to repay Issues related to reverse mortgages Issues related to the Financial Accounting Standards Board (FASB) Issues related to mark-to-market accounting Issues related to private equity standards Issues related to the implementation of the Unlawful Internet Gambling Prohibition Act Issues related to data and cyber security Issues related to mobile banking and mobile payments Issues related to the oversight of the Federal Housing Administration Issues related to USDA Rural Development Loan program Issues related to identity theft and fraud reduction Issues related to student lending Issues related to the Federal Home Loan Bank System Issues related to short term lending products and advance deposit products Issues related to patent reform Issues related to Federal Credit Union bylaws Issues relating to home-based credit unions Issues related to NCUAs risk-based capital proposal Issues related to NCUAs proposed rule on securitization Issues related to NCUAs regulatory review process Issues related to credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union by-laws Issues related to credit unions incidental powers Issues related to credit unions ability to offer prepaid cards Issues related to Ginnie Mae capital Issues related to credit union service to marijuana businesses Issues related to financial literacy Issues related to the Department of Justices investigation entitled, Operation Choke Point Issues related to membership eligibility in the Federal Home Loan Bank System. Issues related to the Department of Defense proposal regarding Credit Extending to Service Members under MLA Issues related to the Economic Growth and Regulatory Paperwork Reduction Act process Issues related to indirect auto lending Issues related to fixed assets Issues related to merchant data breaches Issues related to the payments system Issues related to FHFA proposed rules and FHLB eligibility for credit unions Issues related to Federal Reserve Regulatory D Issues related to 1-4 Family Non-Owner Occupied Residential Loan Treatment as Residential Rather than Business Loans Issues related to the use of Eminent Domain to Seize Performing Mortgage Loans Issues related to Housing Finance Reform Issues related to the implementation of the remittances provisions in the Dodd-Frank Act Issues related to NCUAs proposal rule on Member Business Lending Issues related to NCUAs proposed rule on Interest on Lawyer Trust Accounts (IOLTA) Issues related to credit union service to unbanked and underbanked consumers Issues related to the United States Postal Service Office of Inspector General report related to role of the postal service in financial services Issues related to the Feds implementation of same-day ACH Issues related to the regulation of corporate credit unions Issues related to the CFPBs proposed regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the payday, vehicle title, and similar lending Issues related to the CFPBs consumer complaint database Issues related to NCUAs Fixed Assets rule Issues related to NCUAs definition of small entity H.R. 9, the Innovation Act, all provisions H.R. 185, Regulatory Accountability Act of 2015 H.R. 299, the Capital Access for Small Community Financial Institutions Act of 2015, all provisions H.R. 527, the Small Business Regulatory Flexibility Improvements Act of 2015 H.R. 601, the Eliminate Privacy Notice Confusion Act, all provisions H.R. 685, the Mortgage Choice Act, all provisions H.R. 766, Financial Institution Consumer Protection Act, all provisions H.R. 989, the Capital Access for Small Businesses Jobs Creation Act, all provisions H.R. 1176, the NCUA Budget Transparency Act, all provisions H.R. 1188, the Credit Union Small Business Jobs Creation Act, all provisions H.R. 1195, the Bureau of Consumer Financial Protection Advisory Boards Act, all provisions H.R. 1210, the Portfolio Lending and Mortgage Access Act, H.R. 1233, the Community Lending Enhancement and Regulatory Relief Act of 2015 H.R. 1259, the Helping Expand Lending Practices in Rural Communities Act, all provisions H.R. 1263, Consumer Financial Protection Safety and Soundness Improvement Act of 2015 H.R. 1265, the Bureau Advisory Commission Transparency Act, all provision H.R. 1266, the Financial Products Safety Commission Act of 2015 H.R. 1408, requiring a study of the capital requirements for mortgage servicing assets H.R. 1422, the Credit Union Residential Loan Parity Act H.R. 1480, the SAFE Confidentiality and Privilege Enhancement Act H.R. 1523, Community Bank Access to Capital Act of 2015 H.R. 1529, the Community Institution Mortgage Relief Act Discussion Draft, Data Security and Breach Notification Act of 2015 H.R. 1941, the Financial Institution Examination Fairness and Reform Act H.R. 2205, the Data Security Act H.R. 2213, to provide for a temporary safe harbor from the enforcement of integrated disclosure requirements for mortgage loan transactions under the Real Estate Settlement Procedures Act of 1974 and the Truth in Lending Act, and for other purposes. H.R. 2287, the National Credit Union Administration Budget Transparency Act H.R. 2473, the Preserving Capital Access and Mortgage Liquidity Act H.R. 2896, the TAILOR Act S. 423, the Privacy Notice Modernization Act, all provisions S. 482, the Consumer Financial Protection Bureau Examination Reporting Threshold Act of 2015, all provisions S. 774 Financial Institutions Examination Fairness and Reform Act, all provisions S. 871, the Helping Expand Lending Practices in (HELP) Rural Communities Act S. 924, the National Credit Union Administration Budget Transparency Act S. 961, the Data Security Act S. 1367, a bill to amend the Federal Home Loan Bank Act with respect to membership eligibility of certain institutions S. 1440, the Credit Union Residential Loan Parity Act S. 1484, the Financial Regulatory Improvement Act, Title I The Heck-Stivers Amendment to H.R. 1735, the National Defense Authorization Act, related to the Department of Defenses MLA Database
2015 · second_quarter · Financial Institutions/Investments/Securities
Supplemental capital issues, regulatory issues for credit unions and tax exemption status: HR185; HR 299; HR 601; HR 685; HR 989; HR 1133; HR 1176; HR 1188; HR 1195; HR 1233; HR 1266; HR 1408; HR 1422; HR 1480; HR 1491; HR 1529; HR 1550; HR 1659; HR 1660; HR 1661; HR 1737; HR 1941; HR 2099; HR 2205; HR 2213; HR 2473; HR 2477; HR 2642; S. 423; S. 482; S. 726; S. 774; S. 924; S. 970; S. 1383; S. 1440; S. 1484; S. 1491; data security and cybersecurity; patent reform; FHLB membership rules; CFPB and FSOC reform; and GSE reform.
Client expense: Not reported · Firm income: $40,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2015 · second_quarter · Banking
Issues related to credit union operations Issues related to credit union field of membership Issues related to credit union service organizations Issues related to vacancies on the National Credit Union Administration (NCUA) Board Issues related to NCUAs low income designation regulations Issues related to NCUA examination procedures Issues related to NCUAs regulation regarding its regulatory flexibility program Issues related to NCUAs proposed rule regarding emergency liquidity Issues related to NCUAs rulemaking process Issues related to material loss reports of the NCUA Office of Inspector General Issues related to the authority of the CFPB to exempt credit unions from its rulemaking Issues related to the CFPB proposal related to remittances and international wire transfers Issues related to the proposed CFPB form on RESPA/TILA Issues related to CFPBs Leadership Structure and Installing a Board Rather than Director Issues related to funding the CFPB through the Appropriations Process Issues related to increasing the CFPB Examination Threshold Issues related to conducting a cost-benefit analysis of all CFPB Proposals Issues related to codifying the CFPBs Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to standardizing the definition of mortgage originator Issues related to overdraft protection and check ordering practices Issues related to mortgage servicing Issues related to mortgage loan originator compensation and qualifications Issues related to high-cost mortgage loans (HOEPA) Issues related to the CFPBs proposed rule regarding qualified mortgage / ability to repay Issues related to reverse mortgages Issues related to the Financial Accounting Standards Board (FASB) Issues related to mark-to-market accounting Issues related to private equity standards Issues related to the implementation of the Unlawful Internet Gambling Prohibition Act Issues related to data and cyber security Issues related to mobile banking and mobile payments Issues related to the oversight of the Federal Housing Administration Issues related to USDA Rural Development Loan program Issues related to identity theft and fraud reduction Issues related to student lending Issues related to the Federal Home Loan Bank System Issues related to short term lending products and advance deposit products Issues related to patent reform Issues related to Federal Credit Union bylaws Issues relating to home-based credit unions Issues related to NCUAs risk-based capital proposal Issues related to NCUAs proposed rule on securitization Issues related to NCUAs regulatory review process Issues related to credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union by-laws Issues related to credit unions incidental powers Issues related to credit unions ability to offer prepaid cards Issues related to Ginnie Mae capital Issues related to credit union service to marijuana businesses Issues related to financial literacy Issues related to the Department of Justices investigation entitled, Operation Choke Point Issues related to membership eligibility in the Federal Home Loan Bank System. Issues related to the Department of Defense proposal regarding Credit Extending to Service Members under MLA Issues related to the Economic Growth and Regulatory Paperwork Reduction Act process Issues related to indirect auto lending Issues related to fixed assets Issues related to merchant data breaches Issues related to the payments system Issues related to FHFA proposed rules and FHLB eligibility for credit unions Issues related to Federal Reserve Regulatory D Issues related to 1-4 Family Non-Owner Occupied Residential Loan Treatment as Residential Rather than Business Loans Issues related to the use of Eminent Domain to Seize Performing Mortgage Loans Issues related to Housing Finance Reform Issues related to the implementation of the remittances provisions in the Dodd-Frank Act Issues related to NCUAs proposal rule on Member Business Lending Issues related to NCUAs proposed rule on Interest on Lawyer Trust Accounts (IOLTA) Issues related to credit union service to unbanked and underbanked consumers Issues related to the United States Postal Service Office of Inspector General report related to role of the postal service in financial services Issues related to the Feds implementation of same-day ACH Issues related to the regulation of corporate credit unions Issues related to the CFPBs proposed regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the payday, vehicle title, and similar lending Issues related to the CFPBs consumer complaint database Issues related to NCUAs Fixed Assets rule Issues related to NCUAs definition of small entity H.R. 9, the Innovation Act, all provisions H.R. 185, Regulatory Accountability Act of 2015 H.R. 299, the Capital Access for Small Community Financial Institutions Act of 2015, all provisions H.R. 527, the Small Business Regulatory Flexibility Improvements Act of 2015 H.R. 601, the Eliminate Privacy Notice Confusion Act, all provisions H.R. 685, the Mortgage Choice Act, all provisions H.R. 766, Financial Institution Consumer Protection Act, all provisions H.R. 989, the Capital Access for Small Businesses Jobs Creation Act, all provisions H.R. 1176, the NCUA Budget Transparency Act, all provisions H.R. 1188, the Credit Union Small Business Jobs Creation Act, all provisions H.R. 1195, the Bureau of Consumer Financial Protection Advisory Boards Act, all provisions H.R. 1210, the Portfolio Lending and Mortgage Access Act, H.R. 1233, the Community Lending Enhancement and Regulatory Relief Act of 2015 H.R. 1259, the Helping Expand Lending Practices in Rural Communities Act, all provisions H.R. 1263, Consumer Financial Protection Safety and Soundness Improvement Act of 2015 H.R. 1265, the Bureau Advisory Commission Transparency Act, all provision H.R. 1266, the Financial Products Safety Commission Act of 2015 H.R. 1408, requiring a study of the capital requirements for mortgage servicing assets H.R. 1422, the Credit Union Residential Loan Parity Act H.R. 1480, the SAFE Confidentiality and Privilege Enhancement Act H.R. 1523, Community Bank Access to Capital Act of 2015 H.R. 1529, the Community Institution Mortgage Relief Act Discussion Draft, Data Security and Breach Notification Act of 2015 H.R. 1941, the Financial Institution Examination Fairness and Reform Act H.R. 2205, the Data Security Act H.R. 2213, to provide for a temporary safe harbor from the enforcement of integrated disclosure requirements for mortgage loan transactions under the Real Estate Settlement Procedures Act of 1974 and the Truth in Lending Act, and for other purposes. H.R. 2287, the National Credit Union Administration Budget Transparency Act H.R. 2473, the Preserving Capital Access and Mortgage Liquidity Act H.R. 2896, the TAILOR Act S. 423, the Privacy Notice Modernization Act, all provisions S. 482, the Consumer Financial Protection Bureau Examination Reporting Threshold Act of 2015, all provisions S. 774 Financial Institutions Examination Fairness and Reform Act, all provisions S. 871, the Helping Expand Lending Practices in (HELP) Rural Communities Act S. 924, the National Credit Union Administration Budget Transparency Act S. 961, the Data Security Act S. 1367, a bill to amend the Federal Home Loan Bank Act with respect to membership eligibility of certain institutions S. 1440, the Credit Union Residential Loan Parity Act S. 1484, the Financial Regulatory Improvement Act, Title I The Heck-Stivers Amendment to H.R. 1735, the National Defense Authorization Act, related to the Department of Defenses MLA Database
2015 · second_quarter · Banking
H.R. 1188 - Credit Union Small Business Jobs Creation Act - entire bill relating to increasing credit union member business lending cap; H.R. 989 - Capital Access for Small Businesses and Jobs Act - entire bill relating to supplemental capital ratios for credit unions; H.R. 601 - Eliminate Privacy Notice Confusion Act - entire bill eliminating requirement that financial institutions privacy notices be sent on annual basis and allow such notices to be sent only when privacy policy changes; S. 423 - Privacy Notice Modernization Act of 2013 - same issues as above; S. 177 and draft House bill - Data Security and Breach Notification Act of 2015 - entire bill relating to security procedures and standards for entities maintaining personal data; 12 CFR Parts 700 - 703: Prompt Corrective Action - Risk-Based Capital - National Credit Union Administration proposed rule on risk-based capital requirements for federally insured credit unions; H.R. 1422 & S. 1440 - Credit Union Residential Loan Parity Act - reclassifies a credit union non-owner real estate loan from a business to a residential loan; H.R. 2473 - Preserving Capital Access and Mortgage Liquidity Act of 2015 - provides credit unions parity with comparable sized banks in Federal Home Loan Bank System.
Client expense: Not reported · Firm income: $30,000
Client expense: $590,000 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office
Client expense: $590,000 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office
Government targets: HOUSE OF REPRESENTATIVES, SENATE
Client expense: $940,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Consumer Financial Protection Bureau (CFPB), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), SENATE, Small Business Administration (SBA), Treasury, Dept of
Government targets: HOUSE OF REPRESENTATIVES, SENATE
Client expense: $1,060,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Consumer Financial Protection Bureau (CFPB), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), SENATE, Small Business Administration (SBA), Treasury, Dept of
Client expense: $810,000 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office
Client expense: $810,000 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office
Government targets: HOUSE OF REPRESENTATIVES, SENATE
Client expense: $420,000 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office
Client expense: $420,000 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office
Client expense: $770,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Consumer Financial Protection Bureau (CFPB), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), SENATE, Small Business Administration (SBA), Treasury, Dept of
Client expense: $560,000 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Natl Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office
Client expense: $560,000 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Natl Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office
Government targets: HOUSE OF REPRESENTATIVES, SENATE
Client expense: $1,260,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Consumer Financial Protection Bureau (CFPB), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), SENATE, Small Business Administration (SBA), Treasury, Dept of
Client expense: $400,000 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Natl Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office
Client expense: $400,000 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Natl Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office
Client expense: $960,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Consumer Financial Protection Bureau (CFPB), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), SENATE, Small Business Administration (SBA), Treasury, Dept of
Client expense: $50,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), SENATE
Client expense: $50,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), SENATE
Client expense: $50,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), SENATE
Government targets: HOUSE OF REPRESENTATIVES, SENATE
Client expense: $1,060,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Executive Office of the President (EOP), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Natl Credit Union Administration (NCUA), SENATE, Small Business Administration (SBA), Treasury, Dept of
Client expense: $1,060,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Executive Office of the President (EOP), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Natl Credit Union Administration (NCUA), SENATE, Small Business Administration (SBA), Treasury, Dept of
Government targets: HOUSE OF REPRESENTATIVES, SENATE