Taxpayer Protection and Responsible Resolution Act

HR 2947, Financial Institution Bankruptcy Act of 2016, issues related to financial institution bankruptcy; HR 5983, The Financial CHOICE Act of 2016, issues related to financial institution bankruptcy; HR 5485, Financial Services and General Government Appropriation Act, 2017, issues related to financial institution bankruptcy; S 1840, S 1841, Taxpayer Protection and Responsible Resolution Act, issues related to bankruptcy.

Client expense: $980,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Financial Regulation Reform and Modernization - The Forum supports policies that ensure the safety and soundness of financial institutions, promote financial system stability, and protect depositors, consumers, and investors. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum opposes legislation to preemptively dismantle well-capitalized and well-managed financial institutions, or punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach - capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum supports international coordination on derivatives regulation, and believes U.S. regulators should harmonize policies to avoid confusion. Capital Requirements - The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. The Forum generally supports efforts by the Federal Reserve to impose a total loss absorbing capacity (TLAC) requirement on the largest banking firms to make those firms more resilient and to facilitate orderly resolution. The TLAC rule ensures that all losses resulting from a failure of one of the largest financial institutions are borne by private creditors and shareholders, not the taxpayer. The Forum supports the Federal Reserve utilizing its statutory authority under the Dodd-Frank Act to extend the date for the required sale of banks positions in illiquid funds to 2022. This would conform actual practice with the final rule that governs permitted bank investments in this investment category. The Forum supports Congress reviewing options to enhance the U.S. Bankruptcy Code in order to facilitate the orderly resolution of a failed financial institution. While there are many possible ways to achieve this goal, the Forum would support enactment of H.R. 2947, The Financial Institution Bankruptcy Act of 2016, and S.1841, Taxpayer Protection and Responsible Resolution Act. The Forum opposes the recommendation by the Federal Reserve, FDIC, and OCC that Congress should repeal the provisions of the Gramm-Leach-Bliley Act that permit merchant banking and related authorities. The Forum is of the view that the reasoning offered by the agencies for their recommendation is highly dubious and unpersuasive. Congress and regulators should conduct more robust analysis before moving forward. The Forum is supportive of a number of aspects of H.R.5983: The Financial CHOICE Act of 2016, including reducing unnecessary regulatory burden that undermines credit availability and economic growth, creating a credible and predictable bankruptcy regime for large financial institutions, and reassessing aspects of the Volcker Rule and debit card interchange fees. The CHOICE Acts focus on a 10 percent strict leverage ratio, however, risks overlooking the significant system-strengthening progress already made to date, as well as the reality that additional capital is not without costs or consequences.

Met with House on FinTech Met with House and Senate on large bank issues Met with House and Senate on credit card issues Met with House and Senate staff on capital leverage matters Met with House and Senate staff on flood insurance issues Met with House and Senate issues related to data security and payments system integrity Met with House and Senate on equities market structure reform Met with House and Senate on reauthorization of the Commodities Exchange Act and derivatives regulation Met with House and Senate on bond market issues Draft House Bill - the Main Street Growth Act - all provisions Met with House on draft legislation to amend the Regulation NMS governance structure Met with House on arbitration H.R.22 - the DRIVE Act, Section 52203 - reducing the dividend rate paid on Federal Reserve stock H.R.1266 - the Financial Product Safety Commission Act of 2015 - all provisions H.R.1486 - the Taking Account of Bureaucrats' Spending Act of 2015 - all provisions H.R.1560 - the Protecting Cyber Networks Act - all provisions H.R.1731 - the National Cybersecurity Protection Advancement Act of 2015 - all provisions H.R.1770 - the Data Security and Breach Notification Act of 2015 - application .R.2205 - The Data Security Act of 2015 - all provisions H.R.2209 - To require the appropriate Federal banking agencies to treat certain municipal obligations as level 2B liquid assets, and for other purposes H.R.2947 - the Financial Institution Bankruptcy 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, and for other purposes - all provisions H.R.5983 - The Financial CHOICE Act - all provisions S.456 - Cyber Threat Sharing Act of 2015 - all provisions S.754 - Cybersecurity Information Sharing Act of 2015 - all provisions S.961 - the Data Security Act of 2015 - all provisions S.1709 - 21st Century Glass-Steagall Act of 2015 - all provisions S.1840 - Taxpayer Protection and Responsible Resolution Act - all provisions S.1841 - Taxpayer Protection and Responsible Resolution Act - all provisions 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 - all provisions

H.R. 2209: A bill to require the appropriate Federal banking agencies to treat certain municipal obligations as level 2A liquid assets, and for other purposes; Provisions related bank regulation. H.R. 2947: A bill to amend title 11 of the United States Code in order to facilitate the resolution of an insolvent financial institution in bankruptcy; Provisions related bankruptcy reform. S. 1840: A bill to amend title 11, United States Code to provide for the liquidation, reorganization, or recapitalization of a covered financial corporation, and for other purposes; Provisions related to bankruptcy reform. S. 1841: A bill to amend title 11, United States Code to provide for the liquidation, reorganization, or recapitalization of a covered financial corporation, and for other purposes; Provisions related bankruptcy reform. H.R. 2205: A bill to protect financial information relating to consumers, to require notice of security breaches, and for other purposes; Provisions related to data security. H.R. 4450: A bill to amend title 31, United States Code, to ensure that persons who form corporations or limited liability companies in the United States disclose the beneficial owners of those corporations or limited liability companies, in order to prevent wrongdoers from exploiting United States corporations and limited liability companies for criminal gain, to assist law enforcement in detecting, preventing, and punishing terrorism, money laundering, and other misconduct involving United States corporations and limited liability companies, and for other purposes; Provisions related to AML / BSA. H.R. 5027: A bill to amend the Federal Reserve Act to adjust the circumstances under which Federal reserve bank stock is callable, and for other purposes; Provisions related to Federal Reserve Bank Stock. H.R. 5465: A bill to repeal section 1075 of the Consumer Protection Financial Act of 2010 relating to rules for payment card transactions, and for other purposes; Provisions related to interchange. H.R. 5485: Financial Services and General Government Appropriations Act, 2017; Provisions related to bankruptcy. H.R. 5606: A bill to facilitate better information sharing to assist in the fight against the funding of terrorist activities, and for other purposes; Provisions related to AML / BSA. S. 2040: Justice Against Sponsors of Terrorism Act: A bill to deter terrorism, provide justice for victims, and for other purposes; Provisions related to liability. S. 2489: A bill to ensure that persons who form corporations in the United States disclose the beneficial owners of those corporations, in order to prevent the formation of corporations with hidden owners, stop the misuse of United States corporations by wrongdoers, and assist law enforcement in detecting, preventing, and punishing terrorism, money laundering, tax evasion, and other criminal and civil misconduct involving United States corporations, and for other purposes; Provisions related to AML / BSA. H.R. 5724: Protecting Consumers' Access to Credit Card Act of 2016. A bill to amend the Revised Statutes of the US and the Federal Deposit Insurance Act to require the rate of interset on certain loans remain unchanged after transfer of the loan, and for other purposes; Provisions related to Federal Deposit Insurance Act. H.R. 5983: Financial CHOICE Act of 2016: A bill to create hope and opportunity for consumers, investors and entrepreneurs by ending bailouts and TBTF, holding Washington and Wall Street accountable, eliminating red tape to increase access to capital and credit, and repealing provisions of the DFA that make America less prosperous, less stable, less free, and for other purposes; Provisions related to capital regulation; bankruptcy. S. 961: A bill to protect information relating to consumers, to require notice of security breaches, and for other purposes; Provisions related to payment card transactions. S. 3067: Financial Services and General Government Appropriations Act, 2017: A bill making appropriations for financial services and general government for the FY ending September 30, 2017, and for other purposes; Provisions related to bankruptcy. 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; Provisions related to liquidity coverage ratio. Issues relating to the convention on the law applicable to certain rights in respect of securities held with an intermediary; Provisions related to securities. DFA Title I, Implementation of Title I of Dodd-Frank; Provisions related to financial stability. Orderly Liquidation, Implementation of Title II of Dodd-Frank; Provisions related to bank resolution.

S. 881; H.R. 2289; S. 1484; H.Res. 288; H.R. 1659; H.R. 2947, S. 1840, S. 1841; H.R. 2209; H.R. 22; H.R. 2029; H.R. 4096; H.R. 4166; H.R. 4638; H.R. 2440; HR 5485; S. 1910; S. 337; S.3118; H.R.5592; H.R. 5983; S. 3404 - Discussed implementation of the Basel capital accord and issues related to capital, liquidity, and leverage. Discussed margin issues; the Commodity End-User Relief Act; CFTC reauthorization; SEC and equity market structure reform; and issues related to central clearing parties. Discussed the Financial Regulatory Improvement Act of 2015 and other proposals related to bank structure, capital requirements, capital formation, market structure, and market liquidity. Discussed issues related to financial institution bankruptcy reform, including issues related to resolution and recovery under the Bankruptcy Code. Discussed access to capital for emerging growth companies. Discussed issues related to the liquidity coverage ratio. Discussed budget and revenue measures involving the financial services sector. Discussed the Financial CHOICE act. Discussed the Financial Services and General Government Appropriations bill. Discussed treatment of supervisory information.

Client expense: $650,000 · Firm income: Not reported

Financial Regulation Reform and Modernization - The Forum supports policies that ensure the safety and soundness of financial institutions, promote financial system stability, and protect depositors, consumers, and investors. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum opposes legislation to preemptively dismantle well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, or punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach - capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum supports international coordination on derivatives regulation, and believes U.S. regulators should harmonize policies to avoid confusion. Capital Requirements - The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. The Forum generally supports efforts by the Federal Reserve to impose a total loss absorbing capacity (TLAC) requirement on the largest banking firms to make those firms more resilient and to facilitate orderly resolution. In mid-2016, the Forum joined other associations in writing a comment letter on the proposed TLAC rule to ensure that the details of the rule are appropriately calibrated to work effectively with the business models and capital structures of large banking institutions. The Forum supports the Federal Reserve utilizing its statutory authority under the Dodd-Frank Act to extend the date for the required sale of banks positions in illiquid funds to 2022. This would conform actual practice with the final rule that governs permitted bank investments in this investment category. The Forum supports Congress reviewing options to enhance the U.S. Bankruptcy Code in order to facilitate the orderly resolution of a failed financial institution. While there are many possible ways to achieve this goal, the Forum would support enactment of H.R. 2947, The Financial Institution Bankruptcy Act of 2016, and S.1841, Taxpayer Protection and Responsible Resolution Act. The Forum opposes the recommendation by the Federal Reserve, FDIC, and OCC that Congress should repeal the provisions of the Gramm-Leach-Bliley Act that permit merchant banking and related authorities. The Forum is of the view that the reasoning offered by the agencies for their recommendation is highly dubious and unpersuasive. Congress and regulators should conduct more robust analysis before moving forward. The Forum commends the House Financial Services Committee in addressing the important policy challenges of regulatory balance, ensuring financial stability, and ending too-big-to-fail. The Forum is supportive of a number of aspects of H.R.5983: The Financial CHOICE Act of 2016, including reducing unnecessary regulatory burden that undermines credit availability and economic growth, creating a credible and predictable bankruptcy regime for large financial institutions, and reassessing aspects of the Volcker Rule and debit card interchange fees. The CHOICE Acts focus on a 10 percent strict leverage ratio, however, risks overlooking the significant system-strengthening progress already made to date, as well as the reality that additional capital is not without costs or consequences.

HR 5170, Social Impact Partnerships to Pay for Results Act, issues related to social impact bonds; HR 5485, Financial Services and General Government Appropriations Act, 2017, issues related to bankruptcy; S 1840, S 1841, Taxpayer Protection and Responsible Resolution Act, issues related to bankruptcy; HR 5019, S 3092, Fair Access to Investment Research Act, issues related to research on exchange-traded funds.

Client expense: $480,000 · Firm income: Not reported

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

H.R.2356, Fair Access to Investment Research Act of 2015 (All sections of full text) S.1841, Taxpayer Protection and Responsible Resolution Act (All sections of full text) Discussions regarding dividends of federal reserve banks Monitored 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.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Met with House on FinTech Met with House and Senate on large bank issues Met with House and Senate on credit card issues Met with House and Senate staff on capital leverage matters Met with House and Senate staff on flood insurance issues Met with House and Senate issues related to data security and payments system integrity Met with House and Senate on equities market structure reform Met with House and Senate on reauthorization of the Commodities Exchange Act and derivatives regulation Met with House and Senate on bond market issues Draft House Bill - the Main Street Growth Act - all provisions The Financial CHOICE Act (draft legislation) - all provisions Met with House on draft legislation to amend the Regulation NMS governance structure Met with House on arbitration H.R.22 - the DRIVE Act, Section 52203 - reducing the dividend rate paid on Federal Reserve stock H.R.1266 - the Financial Product Safety Commission Act of 2015 - all provisions H.R.1486 - the Taking Account of Bureaucrats' Spending Act of 2015 - all provisions H.R.1560 - the Protecting Cyber Networks Act - all provisions H.R.1731 - the National Cybersecurity Protection Advancement Act of 2015 - all provisions H.R.1770 - the Data Security and Breach Notification Act of 2015 - application .R.2205 - The Data Security Act of 2015 - all provisions 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.2947 - the Financial Institution Bankruptcy 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, and for other purposes - all provisions S.456 - Cyber Threat Sharing Act of 2015 - all provisions S.754 - Cybersecurity Information Sharing Act of 2015 - all provisions S.961 - the Data Security Act of 2015 - all provisions S.1840 - Taxpayer Protection and Responsible Resolution Act - all provisions S.1841 - Taxpayer Protection and Responsible Resolution Act - all provisions

S. 881; H.R. 2289; S. 1484; H.Res. 288; H.R. 1659; H.R. 2947, S. 1840, S. 1841; H.R. 2209; H.R. 22; H.R. 2029; H.R. 4096; H.R. 4166; H.R. 4638; H.R. 2440; HR 5485; S. 1910; S. 337; S.3118; H.R.5592 - Discussed implementation of the Basel capital accord and issues related to capital, liquidity, and leverage. Discussed margin issues; the Commodity End-User Relief Act; CFTC reauthorization; SEC and equity market structure reform; and issues related to central clearing parties. Discussed the Financial Regulatory Improvement Act of 2015 and other proposals related to bank structure, capital requirements, capital formation, market structure, and market liquidity. Discussed issues related to financial institution bankruptcy reform, including issues related to resolution and recovery under the Bankruptcy Code. Discussed access to capital for emerging growth companies. Discussed issues related to the liquidity coverage ratio. Discussed budget and revenue measures involving the financial services sector. Discussed the Financial CHOICE act. Discussed the Financial Services and General Government Appropriations bill. Discussed treatment of supervisory information.

Client expense: $780,000 · Firm income: Not reported

H.R. 2209: A bill to require the appropriate Federal banking agencies to treat certain municipal obligations as level 2A liquid assets, and for other purposes; Provisions related bank regulation. H.R. 2947: A bill to amend title 11 of the United States Code in order to facilitate the resolution of an insolvent financial institution in bankruptcy; Provisions related bankruptcy reform. S. 1840: A bill to amend title 11, United States Code to provide for the liquidation, reorganization, or recapitalization of a covered financial corporation, and for other purposes; Provisions related to bankruptcy reform. S. 1841: A bill to amend title 11, United States Code to provide for the liquidation, reorganization, or recapitalization of a covered financial corporation, and for other purposes; Provisions related bankruptcy reform. H.R. 2205: A bill to protect financial information relating to consumers, to require notice of security breaches, and for other purposes; Provisions related to data security. H.R. 4450: A bill to amend title 31, United States Code, to ensure that persons who form corporations or limited liability companies in the United States disclose the beneficial owners of those corporations or limited liability companies, in order to prevent wrongdoers from exploiting United States corporations and limited liability companies for criminal gain, to assist law enforcement in detecting, preventing, and punishing terrorism, money laundering, and other misconduct involving United States corporations and limited liability companies, and for other purposes; Provisions related to AML / BSA. H.R. 5027: A bill to amend the Federal Reserve Act to adjust the circumstances under which Federal reserve bank stock is callable, and for other purposes; Provisions related to Federal Reserve Bank Stock. H.R. 5465: A bill to repeal section 1075 of the Consumer Protection Financial Act of 2010 relating to rules for payment card transactions, and for other purposes; Provisions related to interchange. H.R. 5485: Financial Services and General Government Appropriations Act, 2017; Provisions related to bankruptcy. H.R. 5594: A bill to require the establishment of a national strategy for combating the financing of terrorism and related financial crimes, and for other purposes; Provisions related to AML / BSA. H.R. 5602: A bill to amend title 31, U.S. Code, to authorize the Secretary of the Treasury to include all funds when issuing certain geographic targeting orders, and for other purposes; Provisions related to AML / BSA. H.R. 5603: A bill to authorize the Secretary of the Treasury pay rewards under an asset recovery rewards program to help identify and recover stolen assets linked to foreign government corruption and the proceeds of such corruption hidden behind complex financial structures in the U.S. and abroad; Provisions related to AML / BSA. H.R. 5606: A bill to facilitate better information sharing to assist in the fight against the funding of terrorist activities, and for other purposes; Provisions related to AML / BSA. H.R. 5607: A bill to enhance the Department of the Treasury's role in protecting national security, and for other purposes; Provisions related to AML / BSA. S. 2040: Justice Against Sponsors of Terrorism Act: A bill to deter terrorism, provide justice for victims, and for other purposes; Provisions related to liability. S. 2489: A bill to ensure that persons who form corporations in the United States disclose the beneficial owners of those corporations, in order to prevent the formation of corporations with hidden owners, stop the misuse of United States corporations by wrongdoers, and assist law enforcement in detecting, preventing, and punishing terrorism, money laundering, tax evasion, and other criminal and civil misconduct involving United States corporations, and for other purposes; Provisions related to AML / BSA. S. 3024: Small Business Cyber Security Improvements Act of 2016: A bill to improve cyber security for small businesses; Provisions related to Cyber Security. Issues related to Treaty Doc. 112-6; Provisions related to securities law. DFA Title I, Implementation of Title I of Dodd-Frank; Provisions related to bank resolution. Orderly Liquidation, Implementation of Title II of Dodd-Frank; Provisions related to bank resolution.

Financial Regulatory Reform and Modernization - The Forum supports policies that ensure the safety and soundness of financial institutions, promotes financial system stability, and protect the varied interests of depositors, consumers, and investors. The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach - capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. Value of large financial institutions -- The Forum opposes legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services - both of which contribute directly and importantly to economic growth and job creation here at home. The Forum encourages Congress to study the impact of the plan to reduce the rate on annual dividend payments that financial institutions receive on their shares in the Federal Reserve. The reduction in the dividend rate was used as an offset to the cost of reauthorizing the Highway Trust Fund. The Forum is of the view that Congress should ultimately find a more flexible solution that enables these companies to make more credit available to the real economy. The Forum generally supports efforts by the Federal Reserve to impose a total loss absorbing capacity (TLAC) requirement on the largest banking firms to make those firms more resilient and to facilitate an orderly resolution. The Forum joined other associations in writing a comment letter on the proposed TLAC rule to ensure that the details of the rule are appropriately calibrated to work effectively with the business models and capital structures of a variety of different large banking institutions. The Forum supports the Federal Reserve utilizing its statutory authority under the Dodd Frank Act to extend the date for the required sale of banks positions in illiquid funds to 2022. This would conform actual practice with the final rule that governs permitted bank investments in this investment category. The Forum supports Congress reviewing options to enhance the U.S. Bankruptcy Code in order to facilitate the orderly resolution of a failed financial institution. While there are many possible ways to achieve this goal, the Forum would support enactment of H.R. 2947, The Financial Institution Bankruptcy Act of 2016, and S.1841, Taxpayer Protection and Responsible Resolution Act.

Met with House staff on FinTech Met with House and Senate on large bank issues Met with House and Senate on credit card issues Met with House and Senate staff on capital leverage matters Met with House and Senate staff on flood insurance issues Met with House and Senate issues related to data security and payments system integrity Met with House and Senate on equities market structure reform Met with House and Senate on reauthorization of the Commodities Exchange Act and derivatives regulation Met with House and Senate on bond market issues Draft House Bill - the Main Street Growth Act - all provisions H.R.22 - the DRIVE Act, Section 52203 - reducing the dividend rate paid on Federal Reserve stock H.R.1266 - the Financial Product Safety Commission Act of 2015 - all provisions H.R.1486 - the Taking Account of Bureaucrats' Spending Act of 2015 - all provisions H.R.1560 - the Protecting Cyber Networks Act - all provisions H.R.1731 - the National Cybersecurity Protection Advancement Act of 2015 - all provisions H.R.1770 - the Data Security and Breach Notification Act of 2015 - application .R.2205 - The Data Security Act of 2015 - all provisions 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.2947 - the Financial Institution Bankruptcy Act - all provisions S.456 - Cyber Threat Sharing Act of 2015 - all provisions S.754 - Cybersecurity Information Sharing Act of 2015 - all provisions S.961 - the Data Security Act of 2015 - all provisions S.1840 - Taxpayer Protection and Responsible Resolution Act - all provisions S.1841 - Taxpayer Protection and Responsible Resolution Act - all provisions

Client expense: $1,300,000 · Firm income: Not reported

H.R. 766, the Financial Institution Customer Protection Act of 2015 H.R. 1675, the Encouraging Employee Ownership Act of 2015 S. 1841, "Taxpayer Protection and Responsible Resolution Act" Whistleblower Augmented Reward and Nonretaliation (WARN) Act of 2016 H.R. 2896, Taking Account of Institutions with Low Operation Risk Act of 2015 H.R. 3798, the Due Process Restoration Act of 2015 H.R. 4166, the Expanding Proven Financing for American Employers Act H.R. 4139, the Fostering Innovation Act H.R. 4498 , the HALOS Act H.R. 4620, the Preserving Access to CRE Capital Act H.R. 4638, the Main Street Growth Act H.R. 4096, the Investor Clarity and Bank Parity Act The Brokaw Act H.R. 4018, "Consumer Protection and Choice Act" Department of Education Complaint System Corinthian College Student Loan Relief CFTC Funding CFPB Auto Lending Reform Wage Garnishment Payday Lending Reform DoL Fiduciary Rule CFPB Oversight

Client expense: $304,446 · Firm income: Not reported

S. 881; H.R. 2289; S. 1484; H.Res. 288; H.R. 1659; H.R. 2947, S. 1840, S. 1841; H.R. 2209; H.R. 22; H.R. 2029; H.R. 4096; H.R. 4166; H.R. 4638; H.R. 2440 - Discussed implementation of the Basel capital accord and issues related to capital, liquidity, and leverage. Discussed margin issues; the Commodity End-User Relief Act; CFTC reauthorization; SEC and equity market structure reform; and issues related to central clearing parties. Discussed the Financial Regulatory Improvement Act of 2015 and other proposals related to bank structure, capital requirements, capital formation, market structure, and market liquidity. Discussed issues related to financial institution bankruptcy reform, including issues related to resolution and recovery under the Bankruptcy Code. Discussed access to capital for emerging growth companies. Discussed issues related to certain municipal obligations. Discussed budget and revenue measures involving the financial services sector.

Client expense: $820,000 · Firm income: Not reported

H.R.2947-Financial Institution Bankruptcy Act of 2015 S.1841-Taxpayer Protection and Responsible Resolution Act

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 653: A bill to amend section 552 of title 5, United States Code (commonly known as the Freedom of Information Act), to provide for greater public access to information, and for other purposes; Provisions related administrative procedures. H.R. 766: A bill to provide requirements for the appropriate Federal banking agencies when requesting or ordering a depository institution to terminate a specific customer account, to provide for additional requirements related to subpoenas issued under the Financial Institutions Reform, Recovery, and Enforcement Act of 1989, and for other purposes; Provisions related Operation Chokepoint. S. 337: A bill to improve the Freedom of Information Act; Provisions related administrative procedures. S. 961: A bill to protect information relating to consumers, to require notice of security breaches and for other purposes; Provisions related data security. H.R. 2209: A bill to require the appropriate Federal banking agencies to treat certain municipal obligations as level 2A liquid assets, and for other purposes; Provisions related bank regulation. H.R. 2947: A bill to amend title 11 of the United States Code in order to facilitate the resolution of an insolvent financial institution in bankruptcy; Provisions related bankruptcy reform. S. 1840: A bill to amend title 11, United States Code to provide for the liquidation, reorganization, or recapitalization of a covered financial corporation, and for other purposes; Provisions related bank resolution. S. 1841: A bill to amend title 11, United States Code to provide for the liquidation, reorganization, or recapitalization of a covered financial corporation, and for other purposes; Provisions related bankruptcy reform. H.R. 2205: A bill to protect financial information relating to consumers, to require notice of security breaches, and for other purposes; Provisions related to data security. DFA Title I, Implementation of Title I of Dodd-Frank; Provisions related to bank resolution. Orderly Liquidation, Implementation of Title II of Dodd-Frank; Provisions related to bank resolution.

H.R.2947-Financial Institution Bankruptcy Act of 2015 S.1841-Taxpayer Protection and Responsible Resolution Act

Client expense: Not reported · Firm income: $30,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 881; H.R. 2289; S. 1484; H.Res. 288; H.R. 1659; H.R. 2947, S. 1840, S. 1841; H.R. 2209; H.R. 22; H.R. 2029 - Discussed implementation of the Basel capital accord, including the liquidity coverage ratio and the supplementary leverage ratio. Discussed margin issues; the Commodity End-User Relief Act; CFTC reauthorization; SEC and equity market structure reform; and issues related to central clearing parties. Discussed the Financial Regulatory Improvement Act of 2015 and other proposals related to bank structure, capital requirements, capital formation, market structure, and market liquidity. Discussed issues related to financial institution bankruptcy reform, including issues related to resolution and recovery under the Bankruptcy Code. Discussed access to capital for emerging growth companies. Discussed issues related to certain municipal obligations. Discussed issues related to financial services provisions in the budget and reauthorization of the Highway Trust Fund.

Client expense: $910,000 · Firm income: Not reported

H.R. 9: Innovation Act: A bill to amend title 35, United States Code, and the Leahy-Smith America Invents Act to make improvements and technical corrections; Provisions related to patents. H.R. 2209: A bill to require the appropriate Federal banking agencies to treat certain municipal obligations as level 2A liquid assets, and for other purposes; Provisions related bank regulation. H.R. 2947: A bill to amend title 11 of the United States Code in order to facilitate the resolution of an insolvent financial institution in bankruptcy; Provisions related bankruptcy reform. S. 1840: A bill to amend title 11, United States Code to provide for the liquidation, reorganization, or recapitalization of a covered financial corporation, and for other purposes; Provisions related bank resolution. S. 1841: A bill to amend title 11, United States Code to provide for the liquidation, reorganization, or recapitalization of a covered financial corporation, and for other purposes; Provisions related bankruptcy reform. H.R. 2029: Consolidated Appropriations Act, 2016; Provisions related to the reduction of the Federal Reserve dividend. H.R. 1309: Systemic Risk Designation Improvement Act of 2015: A bill to amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to specify when bank holding companies may be subject to certain enhanced supervision; Provisions related to bank regulation. H.R. 1770: A bill to require certain entities who collect and maintain personal information of individuals to secure such information and to provide notice to such individuals in the case of a breach of security involving such information, and for other purposes; Provisions related to data breaches. H.R. 22: Fixing American's Surface Transportation Act; Provisions related to the reduction of the Federal Reserve dividend. H.R. 2205: A bill to protect financial information relating to consumers, to require notice of security breaches, and for other purposes; Provisions related to data security. S. 754: An original bill to improve cybersecurity in the United States through enhanced sharing of information about cybersecurity threats, and for other purposes; Provisions related to cyber security. DFA Title I, Implementation of Title I of Dodd-Frank; Provisions related to bank resolution. Orderly Liquidation, Implementation of Title II of Dodd-Frank; Provisions related to bank resolution.

S. 881; H.R. 2289; S. 1484; H.Res. 288; H.R. 1659; H.R. 2947, S. 1840, S. 1841; H.R. 2209 - Discussed implementation of the Basel capital accord, including the liquidity coverage ratio and the supplementary leverage ratio. Discussed margin issues; the Commodity End-User Relief Act; CFTC reauthorization; SEC and equity market structure reform; and issues related to central clearing parties. Discussed the Financial Regulatory Improvement Act of 2015 and other proposals related to bank structure, capital requirements, capital formation, market structure, and market liquidity. Discussed issues related to financial institution bankruptcy reform, including issues related to resolution and recovery under the Bankruptcy Code. Discussed access to capital for emerging growth companies. Discussed issues related to certain municipal obligations.

Client expense: $870,000 · Firm income: Not reported

The U.S. Commodity Futures Trading Commission reauthorization; regulation of derivatives; treatment of derivatives and physical commodities in bankruptcy; H.R.2289, the Commodity End-User Relief Act; H.R.1317, a bill to amend the Commodity Exchange Act and the Securities Exchange Act of 1934 to specify how clearing requirements apply to certain affiliate transactions, and for other purposes; S.1840, the Taxpayer Protection and Responsible Resolution Act; S.1841, the Taxpayer Protection and Responsible Resolution Act; and S.876, a bill to amend the Commodity Exchange Act to specify how clearing requirements apply to certain affiliate transactions.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Treatment of derivatives and physical commodities in bankruptcy; S.1841, the Taxpayer Protection and Responsible Resolution Act; S.1840, the Taxpayer Protection and Responsible Resolution Act; and S.1841, the Taxpayer Protection and Responsible Resolution Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE