Community Bank Access to Capital Act of 2015

H.R. 766 Financial Institution Customer Protection Act H.R. 1113 Portfolio Lending and Mortgage Access Act H.R. 1188 Credit Union Small Business Jobs Creation Act H.R. 1195 The Bureau of Consumer Financial Protection Small Business Advisory Board Act H.R. 1210 Portfolio Lending and Mortgage Access Act H.R. 1233 CLEAR Relief Act H.R. 1334 Holding Company Registration Threshold Equalization Act of 2015 H.R. 1523 Community Bank Access to Capital Act H.R. 1529 The Community Institution Mortgage Relief Act H.R. 1553 Small Bank Exam Cycle Reform Act H.R. 1660 The Federal Savings Association Charter Flexibility Act H.R. 1661 Mutual Bank Capital Opportunity Act H.R. 1766 Right to Lend Act of 2015 H.R. 2205 Data Security Act of 2015 H.R. 2896 Tailor Act of 2015 H.R. 2987 Community Bank Capital Clarification Act H.R. 3791 A bill to increase Small Bank Holding Policy Statement threshold from $1B to $5B in assets H.R. 4099 CFPB Exam and Reporting Threshold Act H.R. 4116 To amend the Federal Deposit Insurance Act to ensure that reciprocal deposits are not considered to be funds obtained by or through a deposit broker H.R. 4500 The Community Bank Reporting Relief Act H.R. 4909 National Defense Authorization Act of 2017 H.R. 4997 The Home Mortgage Disclosure Adjustment Act H.R. 5076 Main Street Parity Act H.R. 5465 To repeal section 1075 of the Consumer Financial Protection Act of 2010 relating to rules for payment card transactions, and for other purposes. H.R. 5485 Financial Services and General Government Appropriations Act of 2017 H.R. 5724 The Protecting Consumers Access to Credit Act of 2016 H.R. 5808 EGRPRA Review Frequency H.R. 5983 The Financial CHOICE Act S. 812 The CLEAR Relief Act S. 927 CLEAR Relief Plus Act S. 961 Data Security Act of 2015 S. 970 18-Month Exam Cycle S. 1484 Financial Regulatory Improvement Act S. 1491 Community Lender Regulatory Relief and Consumer Protection Act S. 1816 Community Bank Access to Capital Act S. 2471 401 (Kids) Education Savings Account Act of 2016 S. 2722 Federal Savings Association Charter Flexibility Act - all provisions S. 2943 National Defense Authorization Act of 2017 S. 2992 Small Business Lending Oversight Act S. 3067 Financial Services and General Government Appropriations Act of 2017 S. 3153 The Tailor Act. S. 3215 To amend the Home Mortgage Disclosure Act of 1975 to specify which depository institutions are subject to the maintenance of records and disclosure requirements of such Act, and for other purposes S. 3373 A bill to amend the Federal Deposit Insurance Act to ensure that the reciprocal deposits of an insured depository institution are not considered to be funds obtained by or through a deposit broker, and for other purposes S. 3404 A bill to amend the Federal Deposit Insurance Act to require the appropriate Federal banking agencies to treat certain municipal obligations as level 2B liquid assets, and for other purposes Call Report Streamlining Capital Access for Community Banks Capital Rules--Basel III CFPB Data Collection CFPB Overdraft CFPB Reforms/Governance CFPB Small Business Data Collection CFPB Small Dollar/Payday Lending Credit Union Business Lending Powers Credit Union Field of Membership Cybersecurity - Information Sharing Data Security and Breaches De Novo Bank Applications Department of Justice Operation Chokepoint Durbin Debit Interchange and Routing Amendment EMV Chip Migration Escrow Mortgage Requirements FASB Accounting Rules for Loan Loss Reserves Faster Payments Federal Reserve Reform Fintech Limited Bank Charter Flood Insurance Reform Home Mortgage Disclosure Act (HMDA) Regulations Housing Finance Reform Innovation Initiative (FinTech) Interchange Military Bank Leases Military Lending Act Rules Mortgage Lending Reform Mutual Banks Nominations of Allan Landon and Kathryn Dominguez to the Board of Governors of the Federal Reserve System Online/Marketplace Lending Qualified Mortgages, Ability to Repay Rules Regulatory Burden for Community Banks Regulatory and Tax Relief for Community Banks SBA 7(a) Lending Limit Small Bank Holding Company Policy Statement TILA/RESPA Integrated Disclosures Implementation Too Big To Fail Virtual Currency Wells Fargo Account Opening Fraud

Client expense: $860,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Natl Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA), Veterans Affairs, Dept of (VA), White House Office

H.R. 766 Financial Institution Customer Protection Act H.R. 1113 Portfolio Lending and Mortgage Access Act H.R. 1188 Credit Union Small Business Jobs Creation Act H.R. 1195 The Bureau of Consumer Financial Protection Small Business Advisory Board Act H.R. 1210 Portfolio Lending and Mortgage Access Act H.R. 1233 CLEAR Relief Act H.R. 1334 Holding Company Registration Threshold Equalization Act of 2015 H.R. 1486 The Taking Account of Bureaucrat's Spending Act H.R. 1523 Community Bank Access to Capital Act H.R. 1529 The Community Institution Mortgage Relief Act H.R. 1553 Small Bank Exam Cycle Reform Act H.R. 1660 The Federal Savings Association Charter Flexibility Act H.R. 1661 Mutual Bank Capital Opportunity Act H.R. 1766 Right to Lend Act of 2015 H.R. 2205 Data Security Act of 2015 H.R. 2896 Tailor Act of 2015 H.R. 2987 Community Bank Capital Clarification Act H.R. 3705 Financial Regulatory Clarity Act of 2015 H.R. 3791 A bill to increase Small Bank Holding Policy Statement threshold from $1B to $5B in assets H.R. 4099 CFPB Exam and Reporting Threshold Act H.R. 4116 To amend the Federal Deposit Insurance Act to ensure that reciprocal deposits are not considered to be funds obtained by or through a deposit broker H.R. 4500 The Community Bank Reporting Relief Act H.R. 4950 Small Financial Institution Advisory Committees Act of 2016 H.R. 4993 Homeowner Information Privacy Protection Act H.R. 4997 The Home Mortgage Disclosure Adjustment Act H.R. 5027 To amend the Federal Reserve Act to adjust the circumstances under which Federal reserve bank stock is callable, and for other purposes. H.R. 5076 Main Street Parity Act H.R. 5465 To repeal section 1075 of the Consumer Financial Protection Act of 2010 relating to rules for payment card transactions, and for other purposes. H.R. 5485 Financial Services and General Government Appropriations Act of 2017 S. 482 CFPB Exam and Reporting Threshold Act S. 774 Financial Institutions and Exam Fairness Reform S. 812 The CLEAR Relief Act S. 927 CLEAR Relief Plus Act S. 961 Data Security Act of 2015 S. 970 18-Month Exam Cycle S. 1484 Financial Regulatory Improvement Act S. 1491 Community Lender Regulatory Relief and Consumer Protection Act S. 1816 Community Bank Access to Capital Act S. 2471 401 (Kids) Education Savings Account Act of 2016 S. 2722 Federal Savings Association Charter Flexibility Act - all provisions S. 2790 Financial Institutions Customer Protection Act S. 2943 National Defense Authorization Act of 2017 S. 2992 Small Business Lending Oversight Act S. 3067 Financial Services and General Government Appropriations Act of 2017 Call Report Streamlining Capital Access for Community Banks Capital Rules--Basel III CFPB Data Collection CFPB Overdraft CFPB Reforms/Governance CFPB Small Business Data Collection CFPB Small Dollar/Payday Lending Credit Union Business Lending Powers Credit Union Field of Membership Cybersecurity - Information Sharing Data Security and Breaches De Novo Bank Applications Department of Justice Operation Chokepoint EMV Chip Migration Escrow Mortgage Requirements FASB Accounting Rules for Loan Loss Reserves Faster Payments FDIC Small Bank Assessments Federal Reserve Reform Flood Insurance Reform Home Mortgage Disclosure Act (HMDA) Regulations Housing Finance Reform Innovation Initiative (FinTech) Interchange Military Bank Leases Military Lending Act Rules Mortgage Lending Reform Mutual Banks Nomination of Amias Gerety as Treasury Asst Sec for Financial Institutions Nominations of Allan Landon and Kathryn Dominguez to the Board of Governors of the Federal Reserve System Online/Marketplace Lending Qualified Mortgages, Ability to Repay Rules Regulatory Burden for Community Banks Regulatory and Tax Relief for Community Banks Repeal of Durbin Amendment SBA 7(a) Lending Limit Small Bank Holding Company Policy Statement TILA/RESPA Integrated Disclosures Implementation Too Big To Fail Virtual Currency

H.R. 766 Financial Institution Customer Protection Act H.R. 957 The CFPB -IG Act H.R. 1113 Portfolio Lending and Mortgage Access Act H.R. 1188 Credit Union Small Business Jobs Creation Act H.R. 1195 The Bureau of Consumer Financial Protection Small Business Advisory Board Act H.R. 1210 Portfolio Lending and Mortgage Access Act H.R. 1233 CLEAR Relief Act H.R. 1334 Holding Company Registration Threshold Equalization Act of 2015 H.R. 1408 The Community Bank Mortgage Servicing Asset Capital Requirements Study Act H.R. 1422 CU Residential Loan Parity Act H.R. 1523 Community Bank Access to Capital Act H.R. 1529 The Community Institution Mortgage Relief Act H.R. 1553 Small Bank Exam Cycle Reform Act H.R. 1660 The Federal Savings Association Charter Flexibility Act H.R. 1661 Mutual Bank Capital Opportunity Act H.R. 1766 Right to Lend Act of 2015 H.R. 1941 Financial Institutions Examination Fairness and Reform Act H.R. 2029 Consolidated Appropriations Act H.R. 2205 Data Security Act of 2015 H.R. 2213 TRID Safe Harbor Protection H.R. 2896 Tailor Act of 2015 H.R. 2987 Community Bank Capital Clarification Act H.R. 3705 Financial Regulatory Clarity Act of 2015 H.R. 3791 A bill to increase Small Bank Holding Policy Statement threshold from $1B to $5B in assets H.R. 4099 CFPB Exam and Reporting Threshold Act H.R. 4116 To amend the Federal Deposit Insurance Act to ensure that reciprocal deposits are not considered to be funds obtained by or through a deposit broker H.R. 4500 The Community Bank Reporting Relief Act S. 482 CFPB Exam and Reporting Threshold Act S. 774 Financial Institutions and Exam Fairness Reform S. 812 The CLEAR Relief Act S.961 Data Security Act of 2015 S. 927 CLEAR Relief Plus Act S. 970 18-Month Exam Cycle S. 1484 Financial Regulatory Improvement Act S. 1491 Community Lender Regulatory Relief and Consumer Protection Act S. 1711 TRID Safe Harbor Protection S. 1816 Community Bank Access to Capital Act S. 2471 401 (Kids) Education Savings Account Act of 2016 S. 2722 Federal Savings Association Charter Flexibility Act - all provisions Call Report Streamlining Capital Access for Community Banks Capital Rules--Basel III Capital Rules--Treatment of Equity Investment Securities CFPB Data Collection CFPB Overdraft CFPB Reforms/Governance CFPB Small Business Data Collection CFPB Small Dollar/Payday Lending Credit Union Business Lending Powers Credit Union Field of Membership Cybersecurity - Information Sharing Data Security and Breaches De Novo Bank Applications Department of Justice Operation Chokepoint EMV Chip Migration Escrow Mortgage Requirements FASB Accounting Rules for Loan Loss Reserves Faster Payments FDIC Small Bank Assessments Federal Reserve Reform Flood Insurance Reform Home Mortgage Disclosure Act (HMDA) Regulations Housing Finance Reform Innovation Initiative (FinTech) Interchange Military Bank Leases Military Lending Act Rules Mortgage Lending Reform Mutual Banks NCUA Proposed Rule to Extend Member Business Lending, Commercial Lending, Part 72B Nomination of Amias Gerety as Treasury Asst Sec for Financial Institutions Nominations of Allan Landon and Kathryn Dominguez to the Board of Governors of the Federal Reserve System Online/Marketplace Lending Providing Opportunities for Savings, Transactions and Lending Act Qualified Mortgages, Ability to Repay Rules Regulatory Burden for Community Banks Regulatory and Tax Relief for Community Banks Repeal of Durbin Amendment SBA 7(a) Lending Limit Small Bank Holding Company Policy Statement TILA/RESPA Integrated Disclosures Implementation Too Big To Fail Virtual Currency

H.R. 22 Developing a Reliable and Innovating Vision for the Economy -Section 52203 (Fed dividend pay for) H.R. 601 Eliminate Privacy Notice Confusion Act H.R. 766 Financial Institution Customer Protection Act H.R. 888 Subsidy Reserve Act H.R. 957 The CFPB -IG Act H.R. 1113 Portfolio Lending and Mortgage Access Act H.R. 1188 Credit Union Small Business Jobs Creation Act H.R. 1195 The Bureau of Consumer Financial Protection Small Business Advisory Board Act H.R. 1210 Portfolio Lending and Mortgage Access Act H.R. 1233 CLEAR Relief Act H.R. 1259 The HELP Rural Communities Act H.R. 1266 The Financial Products Safety Commission Act H.R. 1334 Holding Company Registration Threshold Equalization Act of 2015 H.R. 1408 The Community Bank Mortgage Servicing Asset Capital Requirements Study Act H.R. 1422 CU Residential Loan Parity Act H.R. 1523 Community Bank Access to Capital Act H.R. 1529 The Community Institution Mortgage Relief Act H.R. 1553 Small Bank Exam Cycle Reform Act H.R. 1660 The Federal Savings Association Charter Flexibility Act H.R. 1661 Mutual Bank Capital Opportunity Act H.R. 1737 The Reforming CFPB Indirect Auto Financing Guidance Act H.R. 1766 Right to Lend Act of 2015 H.R. 1941 Financial Institutions Examination Fairness and Reform Act H.R. 2029 Consolidated Appropriations Act H.R. 2205 Data Security Act of 2015 H.R. 2213 TRID Safe Harbor Protection H.R. 2209 To require the appropriate Federal banking agencies to treat certain municipal obligations as level 2A liquid assets, and for other purposes. H.R. 2896 Tailor Act of 2015 H.R. 2995 FY 2016 Financial Services Approps Bill - Opposed Amendment to Offer HR 1188 Bill H.R. 2987 Community Bank Capital Clarification Act H.R. 3038 Highway and Transportation Funding Act of 2015 (section 2003) H.R. 3048 Community Financial Institution Exemption Act H.R. 3236 Care Choice Improvement Act of 2015 (Highway Trust Fund Act) H.R. 3705 Financial Regulatory Clarity Act of 2015 H.R. 3791 A bill to increase Small Bank Holding Policy Statement threshold from $1B to $5B in assets H.R. 3808 To require the withdrawal and study of the Federal Housing Finance Agencys proposed rule on Federal Home Loan Bank membership H.R. 4116 To amend the Federal Deposit Insurance Act to ensure that the reciprocal deposits are not considered to be funds obtained by or through a deposit broker S. 423 Privacy Notice Modernization Act S. 482 CFPB Exam and Reporting Threshold Act S. 754 Cybersecurity Information Sharing Act of 2015 S. 774 Financial Institutions and Exam Fairness Reform S. 812 The CLEAR Relief Act S. 871 HELP Rural Communities Act S.961 Data Security Act of 2015 S. 927 CLEAR Relief Plus Act S. 970 18-Month Exam Cycle S. 1484 Financial Regulatory Improvement Act S. 1491 Community Lender Regulatory Relief and Consumer Protection Act S. 1647 Developing a Reliable and Innovative Vision for the Economy Act - Fed Reserve Dividend S. 1711 TRID Safe Harbor Protection S. 1816 Community Bank Access to Capital Act S. 1974 The Relationship Lending Preservation Act Appraisal Exemption Basel III/Capital Access Call Report Burden CFPB Data Collection CFPB Overdraft CFPB Reforms/Governance CFPB Small Business Data Collection CFPB Small Dollar/Payday Lending Congressional Payments Technology Caucus Credit Union Business Lending Powers Cybersecurity - Information Sharing Data Security and Breaches De Novo Bank Applications Department of Justice Operation Chokepoint Escrow Mortgage Requirements FASB Accounting Rules for Loan Loss Reserves Faster Payments FDIC Small Bank Assessments Federal Reserve Reform Federal Home Loan Bank Membership Rules Home Mortgage Disclosure Act (HMDA) Regulations House Payments Innovation Caucus Housing Finance Reform Military Lending Act Rules Mortgage Lending Reform Mutual Banks NCUA Proposed Rule to Extend Member Business Lending, Commercial Lending, Part 72B Online/Marketplace Lending Qualified Mortgages, Ability to Repay Rules Reduction in Dividend Rate on Federal Reserve Stock Regulatory Burden for Community Banks Regulatory and Tax Relief for Community Banks SBA 7(a) Lending Limit Senate Payments Innovation Caucus Small Bank Holding Company Policy Statement TILA/RESPA Integrated Disclosures Implementation Too Big To Fail Virtual Currency

H.R. 22 Developing a Reliable and Innovating Vision for the Economy -Section 52203 (Fed dividend pay for) H.R. 601 Eliminate Privacy Notice Confusion Act H.R. 766 Financial Institution Customer Protection Act H.R. 888 Subsidy Reserve Act H.R. 957 The CFPB -IG Act H.R. 1090 The Retail Investor Protection Act H.R. 1113 Portfolio Lending and Mortgage Access Act H.R. 1188 Credit Union Small Business Jobs Creation Act H.R. 1195 The Bureau of Consumer Financial Protection Small Business Advisory Board Act H.R. 1210 Portfolio Lending and Mortgage Access Act H.R. 1233 CLEAR Relief Act H.R. 1259 The HELP Rural Communities Act H.R. 1266 The Financial Products Safety Commission Act H.R. 1334 Holding Company Registration Threshold Equalization Act of 2015 H.R. 1389 American Jobs and Community Revitalization Act H.R. 1408 The Community Bank Mortgage Servicing Asset Capital Requirements Study Act H.R. 1422 CU Residential Loan Parity Act H.R. 1523 Community Bank Access to Capital Act H.R. 1529 The Community Institution Mortgage Relief Act H.R. 1553 Small Bank Exam Cycle Reform Act H.R. 1660 The Federal Savings Association Charter Flexibility Act H.R. 1661 Mutual Bank Capital Opportunity Act H.R. 1737 The Reforming CFPB Indirect Auto Financing Guidance Act H.R. 1766 Right to Lend Act of 2015 H.R. 1941 Financial Institutions Examination Fairness and Reform Act H.R. 1974 Relationship Lending Preservation Act H.R. 2205 Data Security Act of 2015 H.R. 2213 TRID Safe Harbor Protection H.R. 2896 Tailor Act of 2015 H.R. 2995 FY 2016 Financial Services Approps Bill - Opposed Amendment to Offer HR 1188 Bill H.R. 2987 Community Bank Capital Clarification Act H.R. 3038 Highway and Transportation Funding Act of 2015 (section 2003) H.R. 3048 Community Financial Institution Exemption Act H.R. 3192 Homebuyers Assistance Act H.R. 3236 Care Choice Improvement Act of 2015 (Highway Trust Fund Act) S. 423 Privacy Notice Modernization Act S. 482 CFPB Exam and Reporting Threshold Act S. 754 Cybersecurity Information Sharing Act of 2015 S. 774 Financial Institutions and Exam Fairness Reform S. 812 The CLEAR Relief Act S. 871 HELP Rural Communities Act S. 881 A bill to ensure that Federal financial regulators perform a comprehensive review of regulations to identify outdated or otherwise unnecessary regulatory requirements imposed on financial institutions, and for other purposes (EGRPRA) S.961 Data Security Act of 2015 S. 966 Commercial Real Estate and Economic Development Act S. 927 CLEAR Relief Plus Act S. 970 18-Month Exam Cycle S. 1484 Financial Regulatory Improvement Act S. 1491 Community Lender Regulatory Relief and Consumer Protection Act S. 1647 Highway Transportation - Fed Reserve Dividend S. 1711 TRID Safe Harbor Protection S. 1816 Community Bank Access to Capital Act S. 1963 Bureau of Consumer Financial Protection Advisory Board Enhancement Act S. 1974 The Relationship Lending Preservation Act Appraisal Exemption Basel III/Capital Access Call Report Burden CFPB Data Collection CFPB Reforms/Governance CFPB Small Business Data Collection CFPB Small Dollar/Payday Lending Congressional Payments Technology Caucus Credit Union Business Lending Powers Cybersecurity - Information Sharing Data Security and Breaches De Novo Bank Applications Department of Justice Operation Chokepoint Escrow Mortgage Requirements Fair Lending/Disparate Impact FASB Accounting Rules for Loan Loss Reserves Faster Payments FDIC Small Bank Assessments Federal Reserve Reform Federal Home Loan Bank Membership Rules Flood Insurance Reform Implementation of Biggert-Waters Act Home Mortgage Disclosure Act (HMDA) Regulations Housing Finance Reform Military Lending Act Rules Mortgage Escrow Requirements Mortgage Lending Reform Mutual Banks Nomination of Mr. Amias Gerety to serve as Treasury Assistant Secretary for Financial Institutions Online/Marketplace Lending Qualified Mortgages, Ability to Repay Rules Reduction in Dividend Rate on Federal Reserve Stock Regulatory Burden for Community Banks Regulatory and Tax Relief for Community Banks SBA 7(a) Lending Limit Senate Payments Innovation Caucus Small Bank Holding Company Policy Statement Surface Transportation and Veterans Health Telephone Consumer Protection Act Exception Ruling TILA/RESPA Integrated Disclosures Implementation Too Big To Fail Virtual Currency

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate) 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. 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 participate 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. 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. 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) Comment Letters - Comment Letter - CFPB, grace period for enforcement and liability in the implementation, and delay in the implementation of the TRID 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) 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)

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)

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)