Community Bank Access to Capital Act of 2019

Proposals to enhance retirement savings opportunities for employers, employees, and individuals, including self correcting inadvertent plan errors. Small business tax credit. Issues related to Code Section 199A. Issues related to the Department of Labor's regulation defining fiduciary. Required minimum distribution issues. SIMPLE IRAs. H.R. 1938, Small Employer Retirement Savings Auto-Enrollment Credit Act (116th Congress). S. 1770, Retirement Security and Savings Act. S. 321, Retirement Security Act (116th Congress). S. 1272, SIMPLE Plan Modernization Act. H.R. 8083, Preserving Employee Retirement Savings Act (116th Congress). S. 1703, Improving Access to Retirement Savings. H.R. 2954, Securing a Strong Retirement Act. H.R. 8606, To defer the tax of certain sales of employer stock and reduce certain retirement-related excise taxes, and for other purposes (116th Congress). S. 1233, Small Business Tax Fairness and Compliance Simplification Act. H.R. 5376, Build Back Better Act. H.R. 5891, Retirement Improvement and Savings Enhancement Act. S. 2387, Small Business Tax Fairness Act. H.R. 7146/S. 1870, Enhancing Emergency and Retirement Savings Act. H.R. 7310, Protecting Americas Retirement Security Act. H.R. 6782/S. 3712, Auto Reenrollment Act. S. 4808, Enhancing American Retirement Now (EARN) Act. S. 4353, RISE & SHINE Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Proposals to enhance retirement savings opportunities for employers, employees, and individuals, including self correcting inadvertent plan errors. Small business tax credit. Issues related to Code Section 199A. Issues related to the Department of Labor's regulation defining fiduciary. Required minimum distribution issues. SIMPLE IRAs. H.R. 1938, Small Employer Retirement Savings Auto-Enrollment Credit Act (116th Congress). S. 1770, Retirement Security and Savings Act. S. 321, Retirement Security Act (116th Congress). S. 1272, SIMPLE Plan Modernization Act. H.R. 8083, Preserving Employee Retirement Savings Act (116th Congress). S. 1703, Improving Access to Retirement Savings. H.R. 2954, Securing a Strong Retirement Act. H.R. 8606, To defer the tax of certain sales of employer stock and reduce certain retirement-related excise taxes, and for other purposes (116th Congress). S. 1233, Small Business Tax Fairness and Compliance Simplification Act. H.R. 5376, Build Back Better Act. H.R. 5891, Retirement Improvement and Savings Enhancement Act. S. 2387, Small Business Tax Fairness Act. H.R. 7146/S. 1870, Enhancing Emergency and Retirement Savings Act. H.R. 7310, Protecting Americas Retirement Security Act. H.R. 6782/S. 3712, Auto Reenrollment Act. S. 4808, Enhancing American Retirement Now (EARN) Act. S. 4353, RISE & SHINE Act.

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

Proposals to enhance retirement savings opportunities for employers, employees, and individuals, including self correcting inadvertent plan errors. Small business tax credit. Issues related to Code Section 199A. Issues related to the Department of Labor's regulation defining fiduciary. Required minimum distribution issues. SIMPLE IRAs. H.R. 1938, Small Employer Retirement Savings Auto-Enrollment Credit Act (116th Congress). S. 1770, Retirement Security and Savings Act. S. 321, Retirement Security Act (116th Congress). S. 1272, SIMPLE Plan Modernization Act. H.R. 8083, Preserving Employee Retirement Savings Act (116th Congress). S. 1703, Improving Access to Retirement Savings. H.R. 2954, Securing a Strong Retirement Act. H.R. 8606, To defer the tax of certain sales of employer stock and reduce certain retirement-related excise taxes, and for other purposes (116th Congress). S. 1233, Small Business Tax Fairness and Compliance Simplification Act. H.R. 5376, Build Back Better Act. H.R. 5891, Retirement Improvement and Savings Enhancement Act. S. 2387, Small Business Tax Fairness Act. H.R. 7146/S. 1870, Enhancing Emergency and Retirement Savings Act. H.R. 7310, Protecting Americas Retirement Security Act. H.R. 6782/S. 3712, Auto Reenrollment Act. Enhancing American Retirement Now (EARN) Act, as approved by the Senate Finance Committee. S. 4353, RISE & SHINE Act.

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

Proposals to enhance retirement savings opportunities for employers, employees, and individuals, including self correcting inadvertent plan errors. Small business tax credit. Issues related to Code Section 199A. Issues related to the Department of Labor's regulation defining fiduciary. Required minimum distribution issues. SIMPLE IRAs. H.R. 1938, Small Employer Retirement Savings Auto-Enrollment Credit Act (116th Congress). S. 1770, Retirement Security and Savings Act. S. 321, Retirement Security Act (116th Congress). S. 1272, SIMPLE Plan Modernization Act. H.R. 8083, Preserving Employee Retirement Savings Act (116th Congress). S. 1703, Improving Access to Retirement Savings. H.R. 2954, Securing a Strong Retirement Act. H.R. 8606, To defer the tax of certain sales of employer stock and reduce certain retirement-related excise taxes, and for other purposes (116th Congress). S. 1233, Small Business Tax Fairness and Compliance Simplification Act. H.R. 5376, Build Back Better Act. H.R. 5891, Retirement Improvement and Savings Enhancement Act. S. 2387, Small Business Tax Fairness Act. H.R. 7146/S. 1870, Enhancing Emergency and Retirement Savings Act. H.R. 7310, Protecting Americas Retirement Security Act. H.R. 6782/S. 3712, Auto Reenrollment Act. Enhancing American Retirement Now (EARN) Act, as approved by the Senate Finance Committee. S. 4353, RISE & SHINE Act.

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

Proposals to enhance retirement savings opportunities for employers, employees, and individuals, including self correcting inadvertent plan errors. Small business tax credit. Issues related to Code Section 199A. Issues related to the Department of Labor's regulation defining fiduciary. Required minimum distribution issues. SIMPLE IRAs. H.R. 1938, Small Employer Retirement Savings Auto-Enrollment Credit Act (116th Congress). S. 1770, Retirement Security and Savings Act. S. 321, Retirement Security Act (116th Congress). S. 1272, SIMPLE Plan Modernization Act. H.R. 8083, Preserving Employee Retirement Savings Act (116th Congress). S. 1703, Improving Access to Retirement Savings. H.R. 2954, Securing a Strong Retirement Act. H.R. 8606, To defer the tax of certain sales of employer stock and reduce certain retirement-related excise taxes, and for other purposes (116th Congress). S. 1233, Small Business Tax Fairness and Compliance Simplification Act. H.R. 5376, Build Back Better Act. H.R. 5891, Retirement Improvement and Savings Enhancement Act. S. 2387, Small Business Tax Fairness Act. H.R. 7146/S. 1870, Enhancing Emergency and Retirement Savings Act. H.R. 7310, Protecting Americas Retirement Security Act. H.R. 6782/S. 3712, Auto Reenrollment Act

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

Proposals to enhance retirement savings opportunities for employers, employees, and individuals, including self correcting inadvertent plan errors. Small business tax credit. Issues related to Code Section 199A. Issues related to the Department of Labor's regulation defining fiduciary. Required minimum distribution issues. SIMPLE IRAs. H.R. 1938, Small Employer Retirement Savings Auto-Enrollment Credit Act (116th Congress). S. 1770, Retirement Security and Savings Act. S. 321, Retirement Security Act (116th Congress). S. 1272, SIMPLE Plan Modernization Act. H.R. 8083, Preserving Employee Retirement Savings Act (116th Congress). S. 1703, Improving Access to Retirement Savings. H.R. 2954, Securing a Strong Retirement Act. H.R. 8606, To defer the tax of certain sales of employer stock and reduce certain retirement-related excise taxes, and for other purposes (116th Congress). S. 1233, Small Business Tax Fairness and Compliance Simplification Act. H.R. 5376, Build Back Better Act. H.R. 5891, Retirement Improvement and Savings Enhancement Act. S. 2387, Small Business Tax Fairness Act. H.R. 7146/S. 1870, Enhancing Emergency and Retirement Savings Act. H.R. 7310, Protecting Americas Retirement Security Act. H.R. 6782/S. 3712, Auto Reenrollment Act

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

Proposals to enhance retirement savings opportunities for employers, employees, and individuals, including self correcting inadvertent plan errors. Small business tax credit. Issues related to Code Section 199A. Issues related to the Department of Labor's regulation defining fiduciary. Required minimum distribution issues. SIMPLE IRAs. H.R. 1938, Small Employer Retirement Savings Auto-Enrollment Credit Act (116th Congress). S. 1770, Retirement Security and Savings Act. S. 321, Retirement Security Act (116th Congress). S. 1272, SIMPLE Plan Modernization Act. H.R. 8083, Preserving Employee Retirement Savings Act (116th Congress). S. 1703, Improving Access to Retirement Savings. H.R. 2954, Securing a Strong Retirement Act. H.R. 8606, To defer the tax of certain sales of employer stock and reduce certain retirement-related excise taxes, and for other purposes (116th Congress). S. 1233, Small Business Tax Fairness and Compliance Simplification Act. H.R. 5376, Build Back Better Act. H.R. 5891, Retirement Improvement and Savings Enhancement Act. S. 2387, Small Business Tax Fairness Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Proposals to enhance retirement savings opportunities for employers, employees, and individuals, including self correcting inadvertent plan errors. Small business tax credit. Issues related to Code Section 199A. Issues related to the Department of Labor's regulation defining fiduciary. Required minimum distribution issues. SIMPLE IRAs. H.R. 1938, Small Employer Retirement Savings Auto-Enrollment Credit Act (116th Congress). S. 1770, Retirement Security and Savings Act. S. 321, Retirement Security Act (116th Congress). S. 1272, SIMPLE Plan Modernization Act. H.R. 8083, Preserving Employee Retirement Savings Act (116th Congress). S. 1703, Improving Access to Retirement Savings. H.R. 2954, Securing a Strong Retirement Act. H.R. 8606, To defer the tax of certain sales of employer stock and reduce certain retirement-related excise taxes, and for other purposes (116th Congress). S. 1233, Small Business Tax Fairness and Compliance Simplification Act. H.R. 5376, Build Back Better Act. H.R. 5891, Retirement Improvement and Savings Enhancement Act. S. 2387, Small Business Tax Fairness Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Proposals to enhance retirement savings opportunities for employers, employees, and individuals, including self correcting inadvertent plan errors. Small business tax credit. Issues related to Code Section 199A. Issues related to the Department of Labor's regulation defining fiduciary. Required minimum distribution issues. SIMPLE IRAs. H.R. 1938, Small Employer Retirement Savings Auto-Enrollment Credit Act (116th Congress). S. 1770, Retirement Security and Savings Act. S. 321, Retirement Security Act (116th Congress). S. 1272, SIMPLE Plan Modernization Act. H.R. 8083, Preserving Employee Retirement Savings Act (116th Congress). S. 1703, Improving Access to Retirement Savings. H.R. 2954, Securing a Strong Retirement Act. H.R. 8606, To defer the tax of certain sales of employer stock and reduce certain retirement-related excise taxes, and for other purposes (116th Congress). S. 1233, Small Business Tax Fairness and Compliance Simplification Act. H.R. 5376, Build Back Better Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Proposals to enhance retirement savings opportunities for employers, employees, and individuals, including self correcting inadvertent plan errors. Small business tax credit. Issues related to Code Section 199A. Issues related to the Department of Labor's regulation defining fiduciary. Required minimum distribution issues. SIMPLE IRAs. H.R. 1938, Small Employer Retirement Savings Auto-Enrollment Credit Act (116th Congress). S. 1770, Retirement Security and Savings Act. S. 321, Retirement Security Act (116th Congress). S. 1272, SIMPLE Plan Modernization Act. H.R. 8083, Preserving Employee Retirement Savings Act (116th Congress). S. 1703, Improving Access to Retirement Savings. H.R. 2954, Securing a Strong Retirement Act. H.R. 8606, To defer the tax of certain sales of employer stock and reduce certain retirement-related excise taxes, and for other purposes (116th Congress). S. 1233, Small Business Tax Fairness and Compliance Simplification Act. H.R. 5376, Build Back Better Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 113 Consolidated Appropriations Act H.R. 388 Financial Reporting Threshold Modernization H.R. 442 Financial Protection for Our Military Families Act H.R. 748 CARES Act H.R. 925 Updated Heroes Act H.R. 1038 Treasury Dept. to take greater role in Anti-Money Laundering/CFT policy and examinations H.R. 1039 Streamline Currency Transaction Reports and Suspicious Activity Reports H.R. 1595 SAFE Banking Act H.R. 2513 Reforms collection of beneficial ownership information for corporations and LLCs H.R. 3182 Requires agency study of Current Expected Credit Loss standard and delays effective date of standard-CECL Consumer Impact and Study Act of 2019 H.R. 3642 Improving Credit Reporting for All Consumers Act H.R. 5315 Expanding Opportunity in Minority Depository Institutions Act H.R. 5322 Ensuring Diversity in Community Banking Act of 2019 H.R. 6249 Coronavirus Accounting Relief Act H.R. 6364 SECURE Notarization Act H. R. 6385 To provide temporary relief from troubled debt restructuring disclosures, to delay the implementation of certain accounting standards for depository Institutions substantially affected by COVID-19, and for other purposes. H.R. 6395 National Defense Authorization Act for Fiscal Year 2021 H.R. 6776 JOBS Credit Act of 2020 H.R. 6800 HEROES Act H.R. 6821 Small Business Expense Protection Act of 2020 H.R. 7010 Payment Protection Program Flexibility Act of 2020 H.R. 7413 Calculate PPP Forgiveness Act H.R. 7668 FY2021 FSGG Appropriations (Banking amendment provisions) H.R. 7709 Jobs and Neighborhood Enhancement Act H.R. 7777 The Paycheck Protection Small Business Forgiveness Act H.R. 7894 The Paycheck Protection Program Small Business Enhancement Act H.R. 7993 Promoting and Advancing Communities of Color Through Inclusive Lending Act H.R. 8215 Improving Digital Identity Act of 2020 H.R. 8337 Continuing Appropriations Act 2021 (Banking amendment provisions) H.R. 8410 Promoting and Advancing Capital in Underbanked Communities Act H.R. 8631 EIDL Forgiveness Act H.R. 8675 Preventing Regulatory Penalties for PPP Lenders Act H.J. Res 90 Providing for Congressional disapproval of the OCC rule relating to Community Reinvestment Act Regulation S. 1200 SAFE Banking Act S. 1233 Community Bank Access to Capital Act S. 1564 Requires agency study of Current Expected Credit Loss standard and delays effective date of standard S. 2563 Illicit Cash Act S. 2839 Eliminating Corporate Shadow Banking Act of 2019 S. 3502 Community Bank Regulatory Relief Act S. 3533 SECURE Notarization Act S. 3548 CARES Act S. 3612 Small Business Expense Protection Act of 2020 S. 3774 Community Capital Investment Act S. 3841 To protect 2020 recovery rebates for individuals from assignment or garnishment S. 3962 Asset Growth Restriction Act of 2020 S. 4014 Prioritized Paycheck Protection Program Act S. 4049 National Defense Authorization Act for Fiscal Year 2021. Section 2885 creates parity between credit unions and banks located on bases. S. 4116 Reauthorize lending under the Payment Protection Program S. 4117 The Paycheck Protection Program Small Business Forgiveness Act S. 4159 E-SIGN Modernization Act S. 4171 Calculate PPP Forgiveness Act of 2020 S. 4255 Jobs and Neighborhood Enhancement Act S. 4614 Postal Banking Act S. 4914 Prioritized Paycheck Protection Program Act S. 4626 SAFE Data Act S. 4644 - A bill to amend the Federal Deposit Insurance Act to ensure that certain custodial deposits of well capitalized insured depository institutions are not considered to be funds obtained by or through deposit brokers S. 4818 HEROES Small Business Lifeline Act S. 4875 Good Faith PPP Borrowers and Lenders Act S. 4885 EIDL Protection Act S. 4927 EIDL Forgiveness Act Bank Capital and Accounting Relief Bank Secrecy Act/Anti-Money Laundering Rules/Legislation, including Beneficial Ownership Issue Bank Secrecy Act Filing Deadline Extension Request During COVID-19 Emergency Brokered Deposits Call Report Streamlining Cannabis Banking CARES Act, Economic Impact Payments CARES Act, Paycheck Protection Program Implementation Community Bank Access to Capital Community Bank Leverage Ratio Community Development Financial Institutions (CDFI) Fund Appropriations Community Reinvestment Act Modernization Credit Union Business Lending Powers Credit Union Field of Membership Rules Credit Union Growth/Powers/Abusive Behavior Credit Union Acquisitions of Community Banks Credit Union Supplemental Capital Current Expected Credit Losses (CECL) Customer Data Access Customer Due Diligence Rule Cybersecurity Data Security, Breaches and Privacy De novo bank formation Equal treatment between community banks and credit unions when assessing rent and related charges on military bases Exclusion of Paycheck Protection Program Loans from Calculation of Bank Asset Thresholds Faster Payments/Federal Reserve Real Time Gross Settlement System Figure Bank, N.A. Charter Application Fintech Regulatory Requirements Flood Insurance Reauthorization Industrial Loan Corporation Loophole Reforms/Rakuten Deposit Insurance Applications Innovation Initiatives (FinTech/Banking Relationships) Interest Rate Caps Loan Modifications: Regulatory Treatment Main Street Lending Program Minority Depository Institutions Issues Money Transmission Mortgage servicer liquidity facility OCC Proposed Payments Charter Postal Banking Regulatory Burden Relief for Community Banks Regulatory and Tax Relief for Community Banks SBA 7(a) Loan Program Funding and Terms Troubled Debt Restructuring

Bank On Brokered Deposits H.R. 741, TAILOR Act H.R. 133, Consolidated Appropriations Act, 2021 H.R. 189, Financial Institution Customer Protection Act of 2019 H.R. 1595, the Secure and Fair Enforcement (SAFE) Banking Act of 2019 H.R. 3619, Appraisal Fee Transparency Act of 2019 H.R. 5194 / S. 2903 /, Climate Change Financial Risk Act of 2019 H.R. 5315, the Expanding Opportunities for Minority Depository Institutions (MDIs) Act H.R. 5322, the Ensuring Diversity in Community Banking Act of 2019 S. 1200, Secure and Fair Enforcement Banking (SAFE) Act of 2019 S. 1233, Community Bank Access to Capital Sec. 2821 of S. 1790, National Defense Authorization Act of 2020 Section 2885 of S. 4049, National Defense Authorization Act for Fiscal Year 2021 S. 2839, Eliminating Corporate Shadow Banking Act of 2019 Sections 4011 and 4012 of H.R. 748/ S. 3548, CARES Act H.R. 748/ S.3548, CARES Act S___, Immediate Measures to Protect Against COVID-19 Threats (IMPACT) for Small Business Act of 2020 S. 3502, The Community Bank Regulatory Relief Act S. 3962, Asset Growth Restriction Act of 2020 S. 3841, A bill to protect 2020 recovery rebates for individuals from assignment or garnishment, and for other purposes. S. 4159, E-SIGN Modernization Act of 2020 H.R. 6800, HEROES Act H. J. Res. 90, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to Community Reinvestment Act Regulations Central Bank Digital Currency

Client expense: $2,940,000 · Firm income: Not reported

Brokered Deposits H.R. 741, TAILOR Act H.R. 189, Financial Institution Customer Protection Act of 2019 H.R. 1595, the Secure and Fair Enforcement (SAFE) Banking Act of 2019 H.R. 3619, Appraisal Fee Transparency Act of 2019 H.R. 5194 / S. 2903 /, Climate Change Financial Risk Act of 2019 H.R. 5315, the Expanding Opportunities for Minority Depository Institutions (MDIs) Act H.R. 5322, the Ensuring Diversity in Community Banking Act of 2019 S. 1200, Secure and Fair Enforcement Banking (SAFE) Act of 2019 S. 1233, Community Bank Access to Capital Sec. 2821 of S. 1790, National Defense Authorization Act of 2020 Section 2885 of S. 4049, National Defense Authorization Act for Fiscal Year 2021 S. 2839, Eliminating Corporate Shadow Banking Act of 2019 H.R. 748/ S.3548, CARES Act S___, Immediate Measures to Protect Against COVID-19 Threats (IMPACT) for Small Business Act of 2020 S. 3502, The Community Bank Regulatory Relief Act S. 3962, Asset Growth Restriction Act of 2020 S. 3841, A bill to protect 2020 recovery rebates for individuals from assignment or garnishment, and for other purposes. S. 4159, E-SIGN Modernization Act of 2020 H.R. 6800, HEROES Act H. J. Res. 90, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to Community Reinvestment Act Regulations Central Bank Digital Currency

Client expense: $2,930,000 · Firm income: Not reported

H.R. 388 Financial Reporting Threshold Modernization H.R. 442 Financial Protection for Our Military Families Act H.R. 748 CARES Act H.R. 925 Updated Heroes Act H.R. 1038 Treasury Dept. to take greater role in Anti-Money Laundering/CFT policy and examinations H.R. 1039 Streamline Currency Transaction Reports and Suspicious Activity Reports H.R. 1595 SAFE Banking Act H.R. 2513 Reforms collection of beneficial ownership information for corporations and LLCs H.R. 2514 Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act: Makes amendments to Bank Secrecy Act H.R. 3182 Requires agency study of Current Expected Credit Loss standard and delays effective date of standard-CECL Consumer Impact and Study Act of 2019 H.R. 3642 Improving Credit Reporting for All Consumers Act H.R. 5315 Expanding Opportunity in Minority Depository Institutions Act H.R. 5322 Ensuring Diversity in Community Banking Act of 2019 H.R. 6249 Coronavirus Accounting Relief Act H.R. 6364 SECURE Notarization Act H. R. 6385 To provide temporary relief from troubled debt restructuring disclosures, to delay the implementation of certain accounting standards for depository Institutions substantially affected by COVID-19, and for other purposes. H.R. 6395 National Defense Authorization Act for Fiscal Year 2021 H.R. 6776 JOBS Credit Act of 2020 H.R. 6800 HEROES Act H.R. 6821 Small Business Expense Protection Act of 2020 H.R. 7010 Payment Protection Program Flexibility Act of 2020 H.R. 7413 Calculate PPP Forgiveness Act H.R. 7668 FY2021 FSGG Appropriations (Banking amendment provisions) H.R. 7709 Jobs and Neighborhood Enhancement Act H.R. 7777 The Paycheck Protection Small Business Forgiveness Act H.R. 7894 The Paycheck Protection Program Small Business Enhancement Act H.R. 7993 Promoting and Advancing Communities of Color Through Inclusive Lending Act H.R. 8215 Improving Digital Identity Act of 2020 H.R. 8337 Continuing Appropriations Act 2021 (Banking amendment provisions) H.R. 8410 Promoting and Advancing Capital in Underbanked Communities Act H.R. 8631 EIDL Forgiveness Act H.J. Res 90 Providing for Congressional disapproval of the OCC rule relating to Community Reinvestment Act Regulation S. 1200 SAFE Banking Act S. 1233 Community Bank Access to Capital Act S. 1564 Requires agency study of Current Expected Credit Loss standard and delays effective date of standard S. 2563 Illicit Cash Act S. 2839 Eliminating Corporate Shadow Banking Act of 2019 S. 3502 Community Bank Regulatory Relief Act S. 3533 SECURE Notarization Act S. 3548 CARES Act S. 3612 Small Business Expense Protection Act of 2020 S. 3774 Community Capital Investment Act S. 3841 To protect 2020 recovery rebates for individuals from assignment or garnishment S. 3962 Asset Growth Restriction Act of 2020 S. 4014 Prioritized Paycheck Protection Program Act S. 4049 National Defense Authorization Act for Fiscal Year 2021. Section 2885 creates parity between credit unions and banks located on bases. S. 4116 Reauthorize lending under the Payment Protection Program S. 4117 The Paycheck Protection Program Small Business Forgiveness Act S. 4159 E-SIGN Modernization Act S. 4171 Calculate PPP Forgiveness Act of 2020 S. 4255 Jobs and Neighborhood Enhancement Act S. 4614 Postal Banking Act S. 4914 Prioritized Paycheck Protection Program Act S. 4626 SAFE Data Act S. 4644 - A bill to amend the Federal Deposit Insurance Act to ensure that certain custodial deposits of well capitalized insured depository institutions are not considered to be funds obtained by or through deposit brokers Bank Capital and Accounting Relief Bank Secrecy Act/Anti-Money Laundering Rules/Legislation, including Beneficial Ownership Issue Bank Secrecy Act Filing Deadline Extension Request During COVID-19 Emergency Brokered Deposits Call Report Streamlining Cannabis Banking CARES Act, Economic Impact Payments CARES Act, Paycheck Protection Program Implementation Community Bank Access to Capital Community Bank Leverage Ratio Community Development Financial Institutions (CDFI) Fund Appropriations Community Reinvestment Act Modernization Credit Union Business Lending Powers Credit Union Emergency Mergers Credit Union Field of Membership Rules Credit Union Growth/Powers/Abusive Behavior Credit Union Acquisitions of Community Banks Credit Union Supplemental Capital Current Expected Credit Losses (CECL) Customer Due Diligence Rule Cybersecurity Data Security, Breaches and Privacy De novo bank formation Equal treatment between community banks and credit unions when assessing rent and related charges on military bases Exclusion of Paycheck Protection Program Loans from Calculation of Bank Asset Thresholds Extension of the Covered Business Method Faster Payments/Federal Reserve Real Time Gross Settlement System Fintech Regulatory Requirements Flood Insurance Reauthorization GAO Study of Credit Unions Industrial Loan Corporation Loophole Reforms/ Square (ILC) and Rakuten Deposit Insurance Applications Innovation Initiatives (FinTech/Banking Relationships) Loan Modifications: Regulatory Treatment Main Street Lending Program Minority Depository Institutions Issues Mortgage servicer liquidity facility NCUA amendment to definition of low-income credit union OCC Proposed Payments Charter Postal Banking Regulatory Burden Relief for Community Banks Regulatory and Tax Relief for Community Banks SBA 7(a) Loan Program Funding and Terms Troubled Debt Restructuring

H.R. 388 Financial Reporting Threshold Modernization H.R. 442 Financial Protection for Our Military Families Act H.R. 748 CARES Act H.R. 1038 Treasury Dept. to take greater role in Anti-Money Laundering/CFT policy and examinations H.R. 1039 Streamline Currency Transaction Reports and Suspicious Activity Reports H.R. 1491 FINTECH Act of 2019 H.R. 1595 SAFE Banking Act H.R. 2513 Reforms collection of beneficial ownership information for corporations and LLCs H.R. 2514 Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act: Makes amendments to Bank Secrecy Act H.R. 2650 Payment Choice Act of 2019 H.R. 3167 National Flood Insurance Program Reauthorization Act H.R. 3182 Requires agency study of Current Expected Credit Loss standard and delays effective date of standard-CECL Consumer Impact and Study Act of 2019 H.R. 3642 Improving Credit Reporting for All Consumers Act H.R. 3951 Payments Modernization Act of 2019 H.R. 4328 Protecting Innocent Consumers Affected by a Shutdown Act H.R. 5050 Veterans and Consumers Fair Credit Act H.R. 5315 Expanding Opportunity in Minority Depository Institutions Act H.R. 5322 Ensuring Diversity in Community Banking Act of 2019 H.R. 5332 Protecting Your Credit Score Act of 2019 H.R. 6116 Consumer Financial Protection Commission Act H.R. 6249 Coronavirus Accounting Relief Act H.R. 6364 SECURE Notarization Act H. R. 6385 To provide temporary relief from troubled debt restructuring disclosures, to delay the implementation of certain accounting standards for depository Institutions substantially affected by COVID-19, and for other purposes. H.R. 6395 National Defense Authorization Act for Fiscal Year 2021 H.R. 6776 JOBS Credit Act of 2020 H.R. 6782 TRUTH Act H.R. 6800 HEROES Act H.R. 7010 Payment Protection Program Flexibility Act of 2020 H.R. 7413 Calculate PPP Forgiveness Act H.J. Res 90 Providing for Congressional disapproval of the OCC rule relating to Community Reinvestment Act Regulation S. 656 SAFE Lending Act of 2019 S. 1200 SAFE Banking Act S. 1233 Community Bank Access to Capital Act S. 1564 Requires agency study of Current Expected Credit Loss standard and delays effective date of standard S. 1790 Sec. 2821: Equal treatment between community banks and credit unions when assessing rent and related charges. S.2563 Illicit Cash Act S.2839 Eliminating Corporate Shadow Banking Act of 2019 S. 3502 Community Bank Regulatory Relief Act S. 3533 SECURE Notarization Act S. 3548 CARES Act S. 3612 Small Business Expense Protection Act of 2020 S. 3774 Community Capital Investment Act S. 3841 To protect 2020 recovery rebates for individuals from assignment or garnishment S. 3918 Paycheck Protection for Producers Act. Modify PPP terms for farmers and ranchers S. 3962 Asset Growth Restriction Act of 2020 S. 3990 Financial Product Safety Commission Act of 2020 S. 4014 Prioritized Paycheck Protection Program Act S. 4049 National Defense Authorization Act for Fiscal Year 2021. Section 2885 creates parity between credit unions and banks located on bases. S. 4116 Reauthorize lending under the Payment Protection Program S. 4117 The Paycheck Protection Program Small Business Forgiveness Act S. 4159 E-SIGN Modernization Act S. 4171 Calculate PPP Forgiveness Act of 2020 S. 4914 Prioritized Paycheck Protection Program Act Bank Capital and Accounting Relief Bank Qualified Municipal Bonds Bank Secrecy Act/Anti-Money Laundering Rules/Legislation, including Beneficial Ownership Issue Bank Secrecy Act Filing Deadline Extension Request During COVID-19 Emergency Call Report Streamlining Cannabis Banking CARES Act, Economic Impact Payments CARES Act, Paycheck Protection Program Implementation Community Bank Access to Capital Community Bank Leverage Ratio Community Development Financial Institutions (CDFI) Fund Appropriations Community Reinvestment Act Modernization Credit Union Business Lending Powers Credit Union Emergency Mergers Credit Union Field of Membership Rules Credit Union Growth/Powers/Abusive Behavior Credit Union Acquisitions of Community Banks Credit Union Supplemental Capital Current Expected Credit Losses (CECL) Customer Due Diligence Rule Customer-permissioned Data Access Cybersecurity Data Security, Breaches and Privacy Deposit Insurance Coverage Levels Direct Deposit Economic Growth, Regulatory Relief and Consumer Protection Act Implementation Faster Payments/Federal Reserve Real Time Gross Settlement System Fintech Regulatory Requirements Flood Insurance Reauthorization Home Mortgage Disclosure Act (HMDA) Regulations Housing Finance Reform Industrial Loan Corporation Loophole Reforms/ Square (ILC) and Rakuten Deposit Insurance Applications Innovation Initiatives (FinTech/Banking Relationships) Loan Modifications: Regulatory Treatment Main Street Lending Program Minority Depository Institutions Issues Mortgage servicer liquidity facility NCUA amendment to definition of low-income credit union PACE Loans Private Flood Insurance Qualified Mortgages - Ability to Repay Rules Regulation CC--Availability of Funds and Collection of Checks Regulatory Burden Relief for Community Banks Regulatory and Tax Relief for Community Banks Remittance Transfers Rulemaking Delay Request During COVID-19 Emergency SBA 7(a) Loan Program Funding and Terms Telephone Consumer Protection Act Waiver Petition Transaction Account Deposit Insurance Guarantee Program Troubled Debt Restructuring

Brokered Deposits H.R. 741, TAILOR Act H.R. 189, Financial Institution Customer Protection Act of 2019 H.R. 1595, the Secure and Fair Enforcement (SAFE) Banking Act of 2019 H.R. 3619, Appraisal Fee Transparency Act of 2019 H.R. 5194 / S. 2903 /, Climate Change Financial Risk Act of 2019 H.R. 5315, the Expanding Opportunities for Minority Depository Institutions (MDIs) Act H.R. 5322, the Ensuring Diversity in Community Banking Act of 2019 S. 1200, Secure and Fair Enforcement Banking (SAFE) Act of 2019 S. 1233, Community Bank Access to Capital Sec. 2821 of S. 1790, National Defense Authorization Act of 2020 S. 4049, National Defense Authorization Act for Fiscal Year 2021 S. 2839, Eliminating Corporate Shadow Banking Act of 2019 H.R. 748/ S.3548, CARES Act S___, Immediate Measures to Protect Against COVID-19 Threats (IMPACT) for Small Business Act of 2020 S. 3502, The Community Bank Regulatory Relief Act S. 3962, Asset Growth Restriction Act of 2020 S. 3841, A bill to protect 2020 recovery rebates for individuals from assignment or garnishment, and for other purposes. H.R. 6800, HEROES Act H. J. Res. 90, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to Community Reinvestment Act Regulations Central Bank Digital Currency

Client expense: $2,730,000 · Firm income: Not reported

Brokered Deposits H.R. 741, TAILOR Act H.R. 189, Financial Institution Customer Protection Act of 2019 H.R. 1595, the Secure and Fair Enforcement (SAFE) Banking Act of 2019 H.R. 3619, Appraisal Fee Transparency Act of 2019 H.R. 5194 / S. 2903 /, Climate Change Financial Risk Act of 2019 H.R. 5315, the Expanding Opportunities for Minority Depository Institutions (MDIs) Act H.R. 5322, the Ensuring Diversity in Community Banking Act of 2019 S. 1200, Secure and Fair Enforcement Banking (SAFE) Act of 2019 S. 1233, Community Bank Access to Capital Sec. 2821 of S. 1790, National Defense Authorization Act of 2020 S. 2839, Eliminating Corporate Shadow Banking Act of 2019 H.R. 748/ S.3548, CARES Act S___, Immediate Measures to Protect Against COVID-19 Threats (IMPACT) for Small Business Act of 2020 S. 3502, The Community Bank Regulatory Relief Act

Client expense: $2,400,000 · Firm income: Not reported

H.R. 388 Financial Reporting Threshold Modernization H.R. 442 Financial Protection for Our Military Families Act H.R. 748 CARES Act H.R. 799 Federal Worker Credit Protection Act of 2019 H.R. 1038 Treasury Dept. to take greater role in Anti-Money Laundering/CFT policy and examinations H.R. 1039 Streamline Currency Transaction Reports and Suspicious Activity Reports H.R. 1387 CONFRONT Act H.R. 1491 FINTECH Act of 2019 H.R. 1595 SAFE Banking Act H.R. 2445 Self Employed Mortgage Access Act of 2019 H.R. 2513 Reforms collection of beneficial ownership information for corporations and LLCs H.R. 2514 Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act: Makes amendments to Bank Secrecy Act H.R. 3167 National Flood Insurance Program Reauthorization Act H.R. 3182 Requires agency study of Current Expected Credit Loss standard and delays effective date of standard-CECL Consumer Impact and Study Act of 2019 H.R. 3198 Comprehensive Regulatory Review Act: Make changes to EGRPRA Review H.R. 3618 Free Credit Scores for Consumers Act of 2019 H.R. 3621 Student Borrower Credit Improvement Act H.R. 3622 Restoring Unfairly Impaired Credit and Protecting Consumers Act H.R. 3642 Improving Credit Reporting for All Consumers Act H.R. 3939 To require the Fed to carry out a quantitative study of any proposed real-time payment system H.R. 3951 Payments Modernization Act of 2019 H.R. 4328 Protecting Innocent Consumers Affected by a Shutdown Act H.R. 4805 Access Business Credit Act of 2019 H.R. 5050 Veterans and Consumers Fair Credit Act H.R. 5315 Expanding Opportunity in Minority Depository Institutions Act H.R. 5322 Ensuring Diversity in Community Banking Act of 2019 H.R. 5332 Protecting Your Credit Score Act of 2019 H.R. 5574 Preserving Small Business Act of 2020 H.R. 6116 Consumer Financial Protection Commission Act H.R. 6249 Coronavirus Accounting Relief Act H.R. 6364 SECURE Notarization Act H. R. 6385 To provide temporary relief from troubled debt restructuring disclosures, to delay the implementation of certain accounting standards for depository Institutions substantially affected by COVID-19, and for other purposes. S. 540 Self-Employed Mortgage Access Act S. 656 SAFE Lending Act of 2019 S. 1028 States Act S. 1200 SAFE Banking Act S. 1233 Community Bank Access to Capital Act S. 1564 Requires agency study of Current Expected Credit Loss standard and delays effective date of standard S. 1790 Sec. 2821: Equal treatment between community banks and credit unions when assessing rent and related charges. S.2563 Illicit Cash Act S.2839 Eliminating Corporate Shadow Banking Act of 2019 S. 3502 Community Bank Regulatory Relief Act S. 3533 SECURE Notarization Act S. 3548 CARES Act Bank Qualified Municipal Bond Issuance Limit Bank Secrecy Act/Anti-Money Laundering Rules/Legislation, including Beneficial Ownership Issue Bank Secrecy Act Filing Deadline Extension Request During COVID-19 Emergency Call Report Streamlining Cannabis Banking CARES Act, Paycheck Protection Program Implementation CFPB Small Business Loan Data Collection Community Bank Access to Capital Community Bank Leverage Ratio Community Development Financial Institutions (CDFI) Fund Appropriations Community Reinvestment Act Modernization Credit Union Business Lending Powers Credit Union Emergency Mergers Credit Union Field of Membership Rules Credit Union Growth/Powers/Abusive Behavior Credit Union Acquisitions of Community Banks Credit Union Supplemental Capital Current Expected Credit Losses (CECL) Customer Due Diligence Rule Cybersecurity Data Security, Breaches and Privacy Deposit Insurance Coverage Levels Direct Deposit Economic Growth, Regulatory Relief and Consumer Protection Act Implementation Faster Payments/Federal Reserve Real Time Gross Settlement System Flood Insurance Reauthorization Home Mortgage Disclosure Act (HMDA) Regulations Housing Finance Reform IMPACT for Small Business Act Industrial Loan Corporation Loophole Reforms/ Square (ILC) and Rakuten Deposit Insurance Applications Innovation Initiative (FinTech) Loan Modifications: Regulatory Treatment Minority Depository Institutions Issues PACE Loans Private Flood Insurance Qualified Mortgages - Ability to Repay Rules Regulation D, Account Transfer Limit Waiver During COVID-19 Emergency Regulatory Burden Relief for Community Banks Regulatory and Tax Relief for Community Banks Remittance Transfers Rulemaking Delay Request During COVID-19 Emergency SBA 7(a) Loan Program Funding and Terms Support for the Nomination of the Honorable Jovita Carranza to serve as Administrator of the U.S. Small Business Administration (SBA) Telephone Consumer Protection Act Waiver Petition Transaction Account Deposit Insurance Guarantee Program Troubled Debt Restructuring

CBAI Federal Policy Priorities - 2019 The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. The Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country. The swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018. The passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. Credit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders. The United States payments system (System), which is the very foundation of our financial services and economy, must be modernized to meet the demands of consumers and to keep pace with the rest of the world. System improvements must not be dominated by the largest banks and financial firms or private-sector non-banks. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system which requires the Federal Reserve to continue to play a preeminent role in the Systems improvement. The Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks). The Federal Deposit Insurance Corporation (FDIC) Deposit Rate Caps (Rate Caps) impact community banks ability to grow and thrive. The flaws in how the Rate Caps are calculated include: not reflecting competitive funding or investment opportunities; the largest banks extensive branch networks and their too-big-to-fail subsidies have an outsized influence on the Rate Caps; promotional and negotiated rates are excluded which present an incomplete picture of the deposit-rate landscape; and credit unions are omitted which wrongly ignores thousands of financial institutions that are similar to community banks. Also, during safety and soundness examinations for well capitalized banks, FDIC examiners are using the flawed Rate Caps as a benchmark in the analysis of bank liquidity, which inevitably results in faulty conclusions that can impact liquidity in a banks CAMELS rating. Without taking a position on the legalization of cannabis, it is a matter of public safety to have a safe harbor from federal sanctions for financial institutions that choose to serve legally-compliant cannabis-related business in states where cannabis is legal. Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant banking profession in the face of industry consolidation. The Federal Deposit Insurance Corporation (FDIC) has indicated a change in direction to finally get back on the right course. These encouraging signs must be closely monitored to assure that many new banks are chartered each year to help maintain the vitality of the community banking profession. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, which has served our nation well for over 150 years, where chartering and supervision is divided between the federal government and the states. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances on the immense power of the regulators, as well as improved rulemaking - as the benefit of each agencies expertise and experience is brought to bear on complex and controversial issues. The reform of the housing GSEs remains critically important to the future of the housing market and the U.S. economy. American homeowners have benefited from the critical role Fannie Mae and Freddie Mac have played in helping finance homeownership for many decades. The GSEs have provided a steady, reliable source of funding for home mortgage lending through all economic cycles and in all markets. Community banks depend on the GSEs for direct access to the secondary market without having to sell their loans through larger financial institutions that compete with them. The GSEs allow community banks to retain the servicing of the loans they sell, which helps to keep delinquencies and foreclosures low. And, unlike other private investors or aggregators, the GSEs have a mandate to serve all markets at all times which is critical to maintaining liquidity when the markets are experiencing financial stress. Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable and reliable sources of funding for their members . However, given their unique relationship with thousands of community lenders, it may be appropriate for the FHLBs to support their members secondary market activities as aggregators or guarantors for residential mortgage loans, provided their current ability to serve their members is not impeded or threatened. Additionally, the FHFA should not impose an ongoing housing mission asset test on FHLB membership, which would undermine the reliability of FHLB funding. A vibrant agricultural and rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from further cuts or adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Community banks are strong guardians of the security and confidentiality of their customers information and are on the frontline of defending against cyber security threats. Core data security principals in legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants in the payment system should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; a national data security breach and notification standard should replace the current patchwork of state laws; and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations, only to achieve the same superior results they currently attain. Regulations promulgated by the Consumer Financial Protection Bureau CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. The CFPB should not be unduly influencing marketplace behavior by targeting financial institutions, products, services, and practices which it deems to be undesirable or inappropriate regardless of what consumers want. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB, in the Dodd-Frank Act (Section 1022(b)(3)(A), has the statutory authority to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Office of Comptroller of the Currency (OCC) intends to issue special purpose national banking charters to Fintech companies. The OCCs intentions, however, raise many concerns. The very legal authority permitting the OCC to charter Fintechs has been challenged by the Conference of State Bank Supervisors (CSBS) as being fatally flawed. A single regulator acting unilaterally in the chartering, examining, supervising and regulating Fintechs is not in the best interests of the profession, consumers and the economy. Congress must provide the explicit statutory authority to charter Fintechs. If the OCC moves forward, it must guarantee that Fintechs will comply with all banking laws, rules and regulations, and that they be held to the same rigorous safety and soundness standards (e.g., supervision and regulation) that are currently being required of community banks and bank holding companies. Fintechs cannot have the advantages of a national bank charter with limited requirements, regulations and liability. The Financial Accounting Standards Board (FASB) has approved significant revisions to the way community banks reserve for their loan losses (i.e., the Current Expected Credit Loss (CECL) Model). After significant community banker input, FASB agreed to address community banker concerns and revised their Model proposal. The revised CECL is more flexible and scalable for community banks by allowing them to evaluate and adjust loan loss amounts using qualitative factors, historic losses, and their current operating systems such as spreadsheets, narratives and other noncomplex estimation methods. Community bankers and Congress must continue to be vigilant to assure the Model implementation provides a clear, practical and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. There is an emerging threat to the security of consumer data from the proliferation of companies seeking to access bank customer account information (i.e., customer data sharing). The Consumer Financial Protection Bureau (CFPB) is responsible under the Dodd-Frank Act to promulgate this rule. While community banks support responsible innovation in financial products and services, the integrity of consumer data and privacy is only as strong as the weakest link. Community banks are financially sound and take great care in protecting consumer privacy, but non-bank entities are typically not well capitalized, have no significant assets and are financially unable to make restitution in the event of a loss. They must none-the-less be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. The Consumer Financial Protection Bureaus (CFPB) small-dollar lending rule was intended to address its concerns about consumer abuse caused by payday and vehicle title lenders. The proposed rule was too broadly drafted and would have ensnared sensible community bank small-dollar consumer lending. Some exemptions were granted for community banks after a burdensome rulemaking process. Subsequently, the new CFPB Director proposed eliminating the underwriting provision, and the delay in the payment provision was continued by a U.S. District Judge. A carefully monitoring and appropriate action will be required, as the implementation of the rule unfolds, to minimize any negative impact on community banks small-dollar consumer lending. While community banks represent less than 20% of banking industry assets, they make 60% of the small business loans and 80% of agricultural loans. The requirement for reporting small business data collection stems from Section 1071 of the Dodd-Frank Act and is meant to facilitate the enforcement of fair lending laws in small business lending. The data, however, clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks that lack scale and compliance resources, and Section 1071 should either be repealed or community banks should be provided with a meaningful exception. Fraud losses are increasing at community banks and Reg CC needs to keep pace with the technology that banks and their customers are using, both now and particularly as the payments system transitions to real-time. All banks, credit unions, and others who utilize the payments system should be operating on the same level playing field when it comes to return reasons for fraud and acknowledging and communicating about fraud. The recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, OCC) Legislation - Proposed legislation to amend the Bank Holding Company Act to regulate industrial bank holding companies (House, Senate, OCC) SAFE Banking Act (H.R. 1595 and S. 1200) (All Sections), cannabis banking safe harbor (House, Senate, OCC) Enhances Credit Opportunities in Rural America (ECORA) (H.R. 1872 and S.1641) (All Sections), interest earned on agricultural real estate and rural single family home loans would not be taxable (House, Senate, OCC) Community Bank Access to Capital (S.1233) (All Sections), exempting banks under certain thresholds from Sarbanes-Oxley internal control attestations and FDIC annual reports, and revises the SECs definition of investor categories (House, Senate, OCC) Corporate Transparency Act of 2019 and Coordinating Oversight/Illicit Cash Act (H.R. 2513&14 and S. 2563) (All Sections), which amends the Bank Secrecy Act (BSA) to require beneficial ownership information to be collected by the Financial Crimes Enforcement Network (FinCEN) (House, Senate, OCC) Preserving Small Business Lending Act of 2020 (H.R. 5574) (All Sections), regarding Section 1071 of the Dodd-Frank Act about small business data collection (House, Senate, OCC) Letters - Letter to The Honorable Senator Mike D. Crapo regarding request for information about Concerns with Cannabis Banking Legislation (Senate) Comment Letter to the Office of the Comptroller of the Currency (OCC) regarding Permissible Interest on Loans that are Sold, Assigned, or Otherwise Transferred; Docket ID OCC-2019-0027 and RIN 1557-AE73 (OCC) Comment Letter to the Consumer Financial Protection Bureau (CFPB) regarding Request for Information Regarding the Integrated Mortgage Disclosure Under the Real Estate Settlement Procedures Act (Regulation X) and the Truth in Lending Act (Regulation (Z) Rule Assessment; Docket No. CFPB-2019-0055 (CFPB) Letter to the Federal Deposit Insurance Corporation (FDIC) regarding Deposit Insurance Applications for Industrial Loan Companies (FDIC, House) Action Alerts - Action Alert regarding tax-exempt credit unions purchasing taxpaying community banks and Congressional oversight of credit unions (House, Senate) Miscellaneous - Modernization of the CRA, OCC Comment Letter - Reforming the CRA Regulatory Framework, Docket ID OCC-2018-0008 and RIN 1557-AE34 (House) Modernization of the CRA (OCC) Tax-exempt credit unions purchasing taxpaying community banks (House and Senate, OCC) Rural America and Farm Credit System lenders (House, Senate, OCC) Community bank response to Coronavirus (House, Senate) Federal Reserves potential removal of Wells Fargo Asset Cap. (House) Current Expected Credit Loss (CECL) model (OCC)

CBAI Federal Policy Priorities - 2019 The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. The Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country. The swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018. The passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. Credit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders. The United States payments system (System), which is the very foundation of our financial services and economy, must be modernized to meet the demands of consumers and to keep pace with the rest of the world. System improvements must not be dominated by the largest banks and financial firms or private-sector non-banks. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system which requires the Federal Reserve to continue to play a preeminent role in the Systems improvement. The Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks). The Federal Deposit Insurance Corporation (FDIC) Deposit Rate Caps (Rate Caps) impact community banks ability to grow and thrive. The flaws in how the Rate Caps are calculated include: not reflecting competitive funding or investment opportunities; the largest banks extensive branch networks and their too-big-to-fail subsidies have an outsized influence on the Rate Caps; promotional and negotiated rates are excluded which present an incomplete picture of the deposit-rate landscape; and credit unions are omitted which wrongly ignores thousands of financial institutions that are similar to community banks. Also, during safety and soundness examinations for well capitalized banks, FDIC examiners are using the flawed Rate Caps as a benchmark in the analysis of bank liquidity, which inevitably results in faulty conclusions that can impact liquidity in a banks CAMELS rating. Without taking a position on the legalization of cannabis, it is a matter of public safety to have a safe harbor from federal sanctions for financial institutions that choose to serve legally-compliant cannabis-related business in states where cannabis is legal. Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant banking profession in the face of industry consolidation. The Federal Deposit Insurance Corporation (FDIC) has indicated a change in direction to finally get back on the right course. These encouraging signs must be closely monitored to assure that many new banks are chartered each year to help maintain the vitality of the community banking profession. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, which has served our nation well for over 150 years, where chartering and supervision is divided between the federal government and the states. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances on the immense power of the regulators, as well as improved rulemaking - as the benefit of each agencies expertise and experience is brought to bear on complex and controversial issues. The reform of the housing GSEs remains critically important to the future of the housing market and the U.S. economy. American homeowners have benefited from the critical role Fannie Mae and Freddie Mac have played in helping finance homeownership for many decades. The GSEs have provided a steady, reliable source of funding for home mortgage lending through all economic cycles and in all markets. Community banks depend on the GSEs for direct access to the secondary market without having to sell their loans through larger financial institutions that compete with them. The GSEs allow community banks to retain the servicing of the loans they sell, which helps to keep delinquencies and foreclosures low. And, unlike other private investors or aggregators, the GSEs have a mandate to serve all markets at all times which is critical to maintaining liquidity when the markets are experiencing financial stress. Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable and reliable sources of funding for their members . However, given their unique relationship with thousands of community lenders, it may be appropriate for the FHLBs to support their members secondary market activities as aggregators or guarantors for residential mortgage loans, provided their current ability to serve their members is not impeded or threatened. Additionally, the FHFA should not impose an ongoing housing mission asset test on FHLB membership, which would undermine the reliability of FHLB funding. A vibrant agricultural and rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from further cuts or adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Community banks are strong guardians of the security and confidentiality of their customers information and are on the frontline of defending against cyber security threats. Core data security principals in legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants in the payment system should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; a national data security breach and notification standard should replace the current patchwork of state laws; and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations, only to achieve the same superior results they currently attain. Regulations promulgated by the Consumer Financial Protection Bureau CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. The CFPB should not be unduly influencing marketplace behavior by targeting financial institutions, products, services, and practices which it deems to be undesirable or inappropriate regardless of what consumers want. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB, in the Dodd-Frank Act (Section 1022(b)(3)(A), has the statutory authority to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Office of Comptroller of the Currency (OCC) intends to issue special purpose national banking charters to Fintech companies. The OCCs intentions, however, raise many concerns. The very legal authority permitting the OCC to charter Fintechs has been challenged by the Conference of State Bank Supervisors (CSBS) as being fatally flawed. A single regulator acting unilaterally in the chartering, examining, supervising and regulating Fintechs is not in the best interests of the profession, consumers and the economy. Congress must provide the explicit statutory authority to charter Fintechs. If the OCC moves forward, it must guarantee that Fintechs will comply with all banking laws, rules and regulations, and that they be held to the same rigorous safety and soundness standards (e.g., supervision and regulation) that are currently being required of community banks and bank holding companies. Fintechs cannot have the advantages of a national bank charter with limited requirements, regulations and liability. The Financial Accounting Standards Board (FASB) has approved significant revisions to the way community banks reserve for their loan losses (i.e., the Current Expected Credit Loss (CECL) Model). After significant community banker input, FASB agreed to address community banker concerns and revised their Model proposal. The revised CECL is more flexible and scalable for community banks by allowing them to evaluate and adjust loan loss amounts using qualitative factors, historic losses, and their current operating systems such as spreadsheets, narratives and other noncomplex estimation methods. Community bankers and Congress must continue to be vigilant to assure the Model implementation provides a clear, practical and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. There is an emerging threat to the security of consumer data from the proliferation of companies seeking to access bank customer account information (i.e., customer data sharing). The Consumer Financial Protection Bureau (CFPB) is responsible under the Dodd-Frank Act to promulgate this rule. While community banks support responsible innovation in financial products and services, the integrity of consumer data and privacy is only as strong as the weakest link. Community banks are financially sound and take great care in protecting consumer privacy, but non-bank entities are typically not well capitalized, have no significant assets and are financially unable to make restitution in the event of a loss. They must none-the-less be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. The Consumer Financial Protection Bureaus (CFPB) small-dollar lending rule was intended to address its concerns about consumer abuse caused by payday and vehicle title lenders. The proposed rule was too broadly drafted and would have ensnared sensible community bank small-dollar consumer lending. Some exemptions were granted for community banks after a burdensome rulemaking process. Subsequently, the new CFPB Director proposed eliminating the underwriting provision, and the delay in the payment provision was continued by a U.S. District Judge. A carefully monitoring and appropriate action will be required, as the implementation of the rule unfolds, to minimize any negative impact on community banks small-dollar consumer lending. While community banks represent less than 20% of banking industry assets, they make 60% of the small business loans and 80% of agricultural loans. The requirement for reporting small business data collection stems from Section 1071 of the Dodd-Frank Act and is meant to facilitate the enforcement of fair lending laws in small business lending. The data, however, clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks that lack scale and compliance resources, and Section 1071 should either be repealed or community banks should be provided with a meaningful exception. Fraud losses are increasing at community banks and Reg CC needs to keep pace with the technology that banks and their customers are using, both now and particularly as the payments system transitions to real-time. All banks, credit unions, and others who utilize the payments system should be operating on the same level playing field when it comes to return reasons for fraud and acknowledging and communicating about fraud. The recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, OCC) Legislation - Proposed legislation to amend the Bank Holding Company Act to regulate industrial bank holding companies (House, Senate, OCC) SAFE Banking Act (H.R. 1595 and S. 1200) (All Sections), cannabis banking safe harbor (House, Senate, OCC) Enhances Credit Opportunities in Rural America (ECORA) (H.R. 1872 and S.1641) (All Sections), interest earned on agricultural real estate and rural single family home loans would not be taxable (House, Senate, OCC) Community Bank Access to Capital (S.1233) (All Sections), exempting banks under certain thresholds from Sarbanes-Oxley internal control attestations and FDIC annual reports, and revises the SECs definition of investor categories (House, Senate, OCC) Corporate Transparency Act of 2019 and Coordinating Oversight/Illicit Cash Act (H.R. 2513&14 and S. 2563) (All Sections), which amends the Bank Secrecy Act (BSA) to require beneficial ownership information to be collected by the Financial Crimes Enforcement Network (FinCEN) (House, Senate, OCC) Preserving Small Business Lending Act of 2020 (H.R. 5574) (All Sections), regarding Section 1071 of the Dodd-Frank Act about small business data collection (House, Senate, OCC) Letters - Letter to The Honorable Senator Mike D. Crapo regarding request for information about Concerns with Cannabis Banking Legislation (Senate) Comment Letter to the Office of the Comptroller of the Currency (OCC) regarding Permissible Interest on Loans that are Sold, Assigned, or Otherwise Transferred; Docket ID OCC-2019-0027 and RIN 1557-AE73 (OCC) Comment Letter to the Consumer Financial Protection Bureau (CFPB) regarding Request for Information Regarding the Integrated Mortgage Disclosure Under the Real Estate Settlement Procedures Act (Regulation X) and the Truth in Lending Act (Regulation (Z) Rule Assessment; Docket No. CFPB-2019-0055 (CFPB) Letter to the Federal Deposit Insurance Corporation (FDIC) regarding Deposit Insurance Applications for Industrial Loan Companies (FDIC, House) Action Alerts - Action Alert regarding tax-exempt credit unions purchasing taxpaying community banks and Congressional oversight of credit unions (House, Senate) Miscellaneous - Modernization of the CRA, OCC Comment Letter - Reforming the CRA Regulatory Framework, Docket ID OCC-2018-0008 and RIN 1557-AE34 (House) Modernization of the CRA (OCC) Tax-exempt credit unions purchasing taxpaying community banks (House and Senate, OCC) Rural America and Farm Credit System lenders (House, Senate, OCC) Community bank response to Coronavirus (House, Senate) Federal Reserves potential removal of Wells Fargo Asset Cap. (House) Current Expected Credit Loss (CECL) model (OCC)

H.R. 741, TAILOR Act H.R. 189, Financial Institution Customer Protection Act of 2019 H.R. 1595, the Secure and Fair Enforcement (SAFE) Banking Act of 2019 S. 1200, Secure and Fair Enforcement Banking (SAFE) Act of 2019 S. 1233, Community Bank Access to Capital Sec. 2821 of S. 1790, National Defense Authorization Act of 2020

Client expense: $2,435,000 · Firm income: Not reported

H.R. 388 Financial Reporting Threshold Modernization H.R. 442 Financial Protection for Our Military Families Act H.R. 799 Federal Worker Credit Protection Act of 2019 H.R. 1038 Treasury Dept. to take greater role in Anti-Money Laundering/CFT policy and examinations H.R. 1039 Streamline Currency Transaction Reports and Suspicious Activity Reports H.R. 1387 CONFRONT Act H.R. 1491 FINTECH Act of 2019 H.R. 1595 SAFE Banking Act H.R. 2445 Self Employed Mortgage Access Act of 2019 H.R. 2513 Reforms collection of beneficial ownership information for corporations and LLCs H.R. 2514 Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act: Makes amendments to Bank Secrecy Act H.R. 2852 Homebuyer Assistance Act of 2019 H.R. 3167 National Flood Insurance Program Reauthorization Act H.R. 3182 Requires agency study of Current Expected Credit Loss standard and delays effective date of standard-CECL Consumer Impact and Study Act of 2019 H.R. 3198 Comprehensive Regulatory Review Act: Make changes to EGRPRA Review H.R. 3614 Restricting Use of Credit Checks for Employment Decisions Act H.R. 3618 Free Credit Scores for Consumers Act of 2019 H.R. 3621 Student Borrower Credit Improvement Act H.R. 3622 Restoring Unfairly Impaired Credit and Protecting Consumers Act H.R. 3642 Improving Credit Reporting for All Consumers Act H.R. 3939 To require the Fed to carry out a quantitative study of any proposed real-time payment system H.R. 3951 Payments Modernization Act of 2019 H.R. 4328 Protecting Innocent Consumers Affected by a Shutdown Act H.R. 4805 Access Business Credit Act of 2019 H.R. 5050 Veterans and Consumers Fair Credit Act H.R. 5315 Expanding Opportunity in Minority Depository Institutions Act H.R. 5322 Ensuring Diversity in Community Banking Act of 2019 H.R. 5332 Protecting Your Credit Score Act of 2019 S. 540 Self-Employed Mortgage Access Act S. 592 Cybersecurity Disclosure Act of 2019 S. 656 SAFE Lending Act of 2019 S. 1028 States Act S. 1200 SAFE Banking Act S. 1233 Community Bank Access to Capital Act S. 1564 Requires agency study of Current Expected Credit Loss standard and delays effective date of standard S. 1790 Sec. 2821: Equal treatment between community banks and credit unions when assessing rent and related charges. S.2563 Illicit Cash Act S.2839 Eliminating Corporate Shadow Banking Act of 2019 Bank Secrecy Act/Anti-Money Laundering Rules/Legislation, including Beneficial Ownership Issue Call Report Streamlining Cannabis Banking CFPB Small Business Loan Data Collection Community Bank Access to Capital Community Bank Acquisitions by Credit Unions Community Bank Leverage Ratio Community Development Financial Institutions (CDFI) Fund Appropriations Community Reinvestment Act Modernization Credit Union Business Lending Powers Credit Union Emergency Mergers Credit Union Field of Membership Rules Credit Union Growth/Powers/Abusive Behavior Credit Union Supplemental Capital Cryptocurrency Current Expected Credit Losses (CECL) Customer Due Diligence Rule Cybersecurity Data Security, Breaches and Privacy Direct Deposit Economic Growth, Regulatory Relief and Consumer Protection Act Implementation Faster Payments/Federal Reserve Real Time Gross Settlement System Flood Insurance Reauthorization Fed Now Service Home Mortgage Disclosure Act (HMDA) Regulations Housing Finance Reform Industrial Loan Corporation Loophole Reforms/ Square (ILC) and Rakuten Deposit Insurance Applications Innovation Initiative (FinTech) Minority Depository Institutions Issues Private Flood Insurance Qualified Mortgages - Ability to Repay Rules Real-Time Gross Settlement (RTGS) Service/Fed Now Service Regulatory Burden Relief for Community Banks Regulatory and Tax Relief for Community Banks Remittance Transfers SBA 7(a) Loan Program Funding

CBAI Federal Policy Priorities - 2019 The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. The Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country. The swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018. The passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. Credit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders. The United States payments system (System), which is the very foundation of our financial services and economy, must be modernized to meet the demands of consumers and to keep pace with the rest of the world. System improvements must not be dominated by the largest banks and financial firms or private-sector non-banks. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system which requires the Federal Reserve to continue to play a preeminent role in the Systems improvement. The Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks). The Federal Deposit Insurance Corporation (FDIC) Deposit Rate Caps (Rate Caps) impact community banks ability to grow and thrive. The flaws in how the Rate Caps are calculated include: not reflecting competitive funding or investment opportunities; the largest banks extensive branch networks and their too-big-to-fail subsidies have an outsized influence on the Rate Caps; promotional and negotiated rates are excluded which present an incomplete picture of the deposit-rate landscape; and credit unions are omitted which wrongly ignores thousands of financial institutions that are similar to community banks. Also, during safety and soundness examinations for well capitalized banks, FDIC examiners are using the flawed Rate Caps as a benchmark in the analysis of bank liquidity, which inevitably results in faulty conclusions that can impact liquidity in a banks CAMELS rating. Without taking a position on the legalization of cannabis, it is a matter of public safety to have a safe harbor from federal sanctions for financial institutions that choose to serve legally-compliant cannabis-related business in states where cannabis is legal. Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant banking profession in the face of industry consolidation. The Federal Deposit Insurance Corporation (FDIC) has indicated a change in direction to finally get back on the right course. These encouraging signs must be closely monitored to assure that many new banks are chartered each year to help maintain the vitality of the community banking profession. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, which has served our nation well for over 150 years, where chartering and supervision is divided between the federal government and the states. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances on the immense power of the regulators, as well as improved rulemaking - as the benefit of each agencies expertise and experience is brought to bear on complex and controversial issues. The reform of the housing GSEs remains critically important to the future of the housing market and the U.S. economy. American homeowners have benefited from the critical role Fannie Mae and Freddie Mac have played in helping finance homeownership for many decades. The GSEs have provided a steady, reliable source of funding for home mortgage lending through all economic cycles and in all markets. Community banks depend on the GSEs for direct access to the secondary market without having to sell their loans through larger financial institutions that compete with them. The GSEs allow community banks to retain the servicing of the loans they sell, which helps to keep delinquencies and foreclosures low. And, unlike other private investors or aggregators, the GSEs have a mandate to serve all markets at all times which is critical to maintaining liquidity when the markets are experiencing financial stress. Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable and reliable sources of funding for their members . However, given their unique relationship with thousands of community lenders, it may be appropriate for the FHLBs to support their members secondary market activities as aggregators or guarantors for residential mortgage loans, provided their current ability to serve their members is not impeded or threatened. Additionally, the FHFA should not impose an ongoing housing mission asset test on FHLB membership, which would undermine the reliability of FHLB funding. A vibrant agricultural and rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from further cuts or adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Community banks are strong guardians of the security and confidentiality of their customers information and are on the frontline of defending against cyber security threats. Core data security principals in legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants in the payment system should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; a national data security breach and notification standard should replace the current patchwork of state laws; and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations, only to achieve the same superior results they currently attain. Regulations promulgated by the Consumer Financial Protection Bureau CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. The CFPB should not be unduly influencing marketplace behavior by targeting financial institutions, products, services, and practices which it deems to be undesirable or inappropriate regardless of what consumers want. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB, in the Dodd-Frank Act (Section 1022(b)(3)(A), has the statutory authority to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Office of Comptroller of the Currency (OCC) intends to issue special purpose national banking charters to Fintech companies. The OCCs intentions, however, raise many concerns. The very legal authority permitting the OCC to charter Fintechs has been challenged by the Conference of State Bank Supervisors (CSBS) as being fatally flawed. A single regulator acting unilaterally in the chartering, examining, supervising and regulating Fintechs is not in the best interests of the profession, consumers and the economy. Congress must provide the explicit statutory authority to charter Fintechs. If the OCC moves forward, it must guarantee that Fintechs will comply with all banking laws, rules and regulations, and that they be held to the same rigorous safety and soundness standards (e.g., supervision and regulation) that are currently being required of community banks and bank holding companies. Fintechs cannot have the advantages of a national bank charter with limited requirements, regulations and liability. The Financial Accounting Standards Board (FASB) has approved significant revisions to the way community banks reserve for their loan losses (i.e., the Current Expected Credit Loss (CECL) Model). After significant community banker input, FASB agreed to address community banker concerns and revised their Model proposal. The revised CECL is more flexible and scalable for community banks by allowing them to evaluate and adjust loan loss amounts using qualitative factors, historic losses, and their current operating systems such as spreadsheets, narratives and other noncomplex estimation methods. Community bankers and Congress must continue to be vigilant to assure the Model implementation provides a clear, practical and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. There is an emerging threat to the security of consumer data from the proliferation of companies seeking to access bank customer account information (i.e., customer data sharing). The Consumer Financial Protection Bureau (CFPB) is responsible under the Dodd-Frank Act to promulgate this rule. While community banks support responsible innovation in financial products and services, the integrity of consumer data and privacy is only as strong as the weakest link. Community banks are financially sound and take great care in protecting consumer privacy, but non-bank entities are typically not well capitalized, have no significant assets and are financially unable to make restitution in the event of a loss. They must none-the-less be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. The Consumer Financial Protection Bureaus (CFPB) small-dollar lending rule was intended to address its concerns about consumer abuse caused by payday and vehicle title lenders. The proposed rule was too broadly drafted and would have ensnared sensible community bank small-dollar consumer lending. Some exemptions were granted for community banks after a burdensome rulemaking process. Subsequently, the new CFPB Director proposed eliminating the underwriting provision, and the delay in the payment provision was continued by a U.S. District Judge. A carefully monitoring and appropriate action will be required, as the implementation of the rule unfolds, to minimize any negative impact on community banks small-dollar consumer lending. While community banks represent less than 20% of banking industry assets, they make 60% of the small business loans and 80% of agricultural loans. The requirement for reporting small business data collection stems from Section 1071 of the Dodd-Frank Act and is meant to facilitate the enforcement of fair lending laws in small business lending. The data, however, clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks that lack scale and compliance resources, and Section 1071 should either be repealed or community banks should be provided with a meaningful exception. Fraud losses are increasing at community banks and Reg CC needs to keep pace with the technology that banks and their customers are using, both now and particularly as the payments system transitions to real-time. All banks, credit unions, and others who utilize the payments system should be operating on the same level playing field when it comes to return reasons for fraud and acknowledging and communicating about fraud. The recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, OCC, Federal Reserve, CFPB) Legislation - Enhances Credit Opportunities in Rural America (ECORA) (H.R. 1872 and S.1641) (All Sections), interest earned on agricultural real estate and rural single family home loans would not be taxable (House and Senate, OCC, CFPB) Community Bank Access to Capital (S.1233) (All Sections), exempting banks under certain thresholds from Sarbanes-Oxley internal control attestations and FDIC annual reports, and revises the SECs definition of investor categories (House and Senate, OCC, CFPB) Corporate Transparency Act of 2019 (H.R. 2513) (All Sections), which amends the Bank Secrecy Act (BSA) to require beneficial ownership information to be collected by the Financial Crimes Enforcement Network (FinCEN) (House) Letters - Comment Letter to the Department of Housing and Urban Development (HUD) regarding HUDs implementation of the Fair Housing Acts Disparate Impact standard; Docket No FR-6111-P-02 and RIN 2529-AA98 (HUD) Comment Letter to the Federal Deposit Insurance Corporation (FDIC) regarding interest rate restrictions on institutions that are less than well capitalized (Deposit Rate Caps); RIN 3064-AF02 (FDIC) Comment Letter to the Federal Reserve regarding Notice and Request for Comments - Federal Reserve actions to support interbank settlement of faster payments [FedNow Service] (Federal Reserve) Comment Letter to the National Credit Union Administration (NCUA) regarding proposed rule about serving core-based/urban statistical areas (NCUA) Action Alerts - Action Alert regarding proposal to increase the Home Mortgage Disclosure Act (HMDA) thresholds for collecting and reporting data (CFPB) Action Alert regarding the Corporate Transparency Act of 2019 (H.R. 2513) (all Sections), which amends the Bank Secrecy Act (BSA) to require beneficial ownership information to be collected by the Financial Crimes Enforcement Network (FinCEN) (House) Action Alert regarding the Federal Reserves implementation of its FedNow (faster payments) Service (Federal Reserve) Action Alert regarding the National Credit Union Administration (NCUA) proposed rule about serving core-based/urban statistical areas (NCUA) Miscellaneous - Tax-exempt credit unions purchasing taxpaying community banks (House and Senate, OCC, CFPB) FDIC Listening Session on Supervisory Appeals and Dispute Resolution Process (FDIC) Closing the supervisory loophole for Industrial Loan Corporations (ILCs) (House)

CBAI Federal Policy Priorities - 2019 The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. The Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country. The swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018. The passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. Credit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders. The United States payments system (System), which is the very foundation of our financial services and economy, must be modernized to meet the demands of consumers and to keep pace with the rest of the world. System improvements must not be dominated by the largest banks and financial firms or private-sector non-banks. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system which requires the Federal Reserve to continue to play a preeminent role in the Systems improvement. The Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks). The Federal Deposit Insurance Corporation (FDIC) Deposit Rate Caps (Rate Caps) impact community banks ability to grow and thrive. The flaws in how the Rate Caps are calculated include: not reflecting competitive funding or investment opportunities; the largest banks extensive branch networks and their too-big-to-fail subsidies have an outsized influence on the Rate Caps; promotional and negotiated rates are excluded which present an incomplete picture of the deposit-rate landscape; and credit unions are omitted which wrongly ignores thousands of financial institutions that are similar to community banks. Also, during safety and soundness examinations for well capitalized banks, FDIC examiners are using the flawed Rate Caps as a benchmark in the analysis of bank liquidity, which inevitably results in faulty conclusions that can impact liquidity in a banks CAMELS rating. Without taking a position on the legalization of cannabis, it is a matter of public safety to have a safe harbor from federal sanctions for financial institutions that choose to serve legally-compliant cannabis-related business in states where cannabis is legal. Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant banking profession in the face of industry consolidation. The Federal Deposit Insurance Corporation (FDIC) has indicated a change in direction to finally get back on the right course. These encouraging signs must be closely monitored to assure that many new banks are chartered each year to help maintain the vitality of the community banking profession. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, which has served our nation well for over 150 years, where chartering and supervision is divided between the federal government and the states. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances on the immense power of the regulators, as well as improved rulemaking - as the benefit of each agencies expertise and experience is brought to bear on complex and controversial issues. The reform of the housing GSEs remains critically important to the future of the housing market and the U.S. economy. American homeowners have benefited from the critical role Fannie Mae and Freddie Mac have played in helping finance homeownership for many decades. The GSEs have provided a steady, reliable source of funding for home mortgage lending through all economic cycles and in all markets. Community banks depend on the GSEs for direct access to the secondary market without having to sell their loans through larger financial institutions that compete with them. The GSEs allow community banks to retain the servicing of the loans they sell, which helps to keep delinquencies and foreclosures low. And, unlike other private investors or aggregators, the GSEs have a mandate to serve all markets at all times which is critical to maintaining liquidity when the markets are experiencing financial stress. Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable and reliable sources of funding for their members . However, given their unique relationship with thousands of community lenders, it may be appropriate for the FHLBs to support their members secondary market activities as aggregators or guarantors for residential mortgage loans, provided their current ability to serve their members is not impeded or threatened. Additionally, the FHFA should not impose an ongoing housing mission asset test on FHLB membership, which would undermine the reliability of FHLB funding. A vibrant agricultural and rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from further cuts or adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Community banks are strong guardians of the security and confidentiality of their customers information and are on the frontline of defending against cyber security threats. Core data security principals in legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants in the payment system should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; a national data security breach and notification standard should replace the current patchwork of state laws; and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations, only to achieve the same superior results they currently attain. Regulations promulgated by the Consumer Financial Protection Bureau CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. The CFPB should not be unduly influencing marketplace behavior by targeting financial institutions, products, services, and practices which it deems to be undesirable or inappropriate regardless of what consumers want. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB, in the Dodd-Frank Act (Section 1022(b)(3)(A), has the statutory authority to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Office of Comptroller of the Currency (OCC) intends to issue special purpose national banking charters to Fintech companies. The OCCs intentions, however, raise many concerns. The very legal authority permitting the OCC to charter Fintechs has been challenged by the Conference of State Bank Supervisors (CSBS) as being fatally flawed. A single regulator acting unilaterally in the chartering, examining, supervising and regulating Fintechs is not in the best interests of the profession, consumers and the economy. Congress must provide the explicit statutory authority to charter Fintechs. If the OCC moves forward, it must guarantee that Fintechs will comply with all banking laws, rules and regulations, and that they be held to the same rigorous safety and soundness standards (e.g., supervision and regulation) that are currently being required of community banks and bank holding companies. Fintechs cannot have the advantages of a national bank charter with limited requirements, regulations and liability. The Financial Accounting Standards Board (FASB) has approved significant revisions to the way community banks reserve for their loan losses (i.e., the Current Expected Credit Loss (CECL) Model). After significant community banker input, FASB agreed to address community banker concerns and revised their Model proposal. The revised CECL is more flexible and scalable for community banks by allowing them to evaluate and adjust loan loss amounts using qualitative factors, historic losses, and their current operating systems such as spreadsheets, narratives and other noncomplex estimation methods. Community bankers and Congress must continue to be vigilant to assure the Model implementation provides a clear, practical and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. There is an emerging threat to the security of consumer data from the proliferation of companies seeking to access bank customer account information (i.e., customer data sharing). The Consumer Financial Protection Bureau (CFPB) is responsible under the Dodd-Frank Act to promulgate this rule. While community banks support responsible innovation in financial products and services, the integrity of consumer data and privacy is only as strong as the weakest link. Community banks are financially sound and take great care in protecting consumer privacy, but non-bank entities are typically not well capitalized, have no significant assets and are financially unable to make restitution in the event of a loss. They must none-the-less be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. The Consumer Financial Protection Bureaus (CFPB) small-dollar lending rule was intended to address its concerns about consumer abuse caused by payday and vehicle title lenders. The proposed rule was too broadly drafted and would have ensnared sensible community bank small-dollar consumer lending. Some exemptions were granted for community banks after a burdensome rulemaking process. Subsequently, the new CFPB Director proposed eliminating the underwriting provision, and the delay in the payment provision was continued by a U.S. District Judge. A carefully monitoring and appropriate action will be required, as the implementation of the rule unfolds, to minimize any negative impact on community banks small-dollar consumer lending. While community banks represent less than 20% of banking industry assets, they make 60% of the small business loans and 80% of agricultural loans. The requirement for reporting small business data collection stems from Section 1071 of the Dodd-Frank Act and is meant to facilitate the enforcement of fair lending laws in small business lending. The data, however, clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks that lack scale and compliance resources, and Section 1071 should either be repealed or community banks should be provided with a meaningful exception. Fraud losses are increasing at community banks and Reg CC needs to keep pace with the technology that banks and their customers are using, both now and particularly as the payments system transitions to real-time. All banks, credit unions, and others who utilize the payments system should be operating on the same level playing field when it comes to return reasons for fraud and acknowledging and communicating about fraud. The recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, OCC, Federal Reserve, CFPB) Legislation - Enhances Credit Opportunities in Rural America (ECORA) (H.R. 1872 and S.1641) (All Sections), interest earned on agricultural real estate and rural single family home loans would not be taxable (House and Senate, OCC, CFPB) Community Bank Access to Capital (S.1233) (All Sections), exempting banks under certain thresholds from Sarbanes-Oxley internal control attestations and FDIC annual reports, and revises the SECs definition of investor categories (House and Senate, OCC, CFPB) Corporate Transparency Act of 2019 (H.R. 2513) (All Sections), which amends the Bank Secrecy Act (BSA) to require beneficial ownership information to be collected by the Financial Crimes Enforcement Network (FinCEN) (House) Letters - Comment Letter to the Department of Housing and Urban Development (HUD) regarding HUDs implementation of the Fair Housing Acts Disparate Impact standard; Docket No FR-6111-P-02 and RIN 2529-AA98 (HUD) Comment Letter to the Federal Deposit Insurance Corporation (FDIC) regarding interest rate restrictions on institutions that are less than well capitalized (Deposit Rate Caps); RIN 3064-AF02 (FDIC) Comment Letter to the Federal Reserve regarding Notice and Request for Comments - Federal Reserve actions to support interbank settlement of faster payments [FedNow Service] (Federal Reserve) Comment Letter to the National Credit Union Administration (NCUA) regarding proposed rule about serving core-based/urban statistical areas (NCUA) Action Alerts - Action Alert regarding proposal to increase the Home Mortgage Disclosure Act (HMDA) thresholds for collecting and reporting data (CFPB) Action Alert regarding the Corporate Transparency Act of 2019 (H.R. 2513) (all Sections), which amends the Bank Secrecy Act (BSA) to require beneficial ownership information to be collected by the Financial Crimes Enforcement Network (FinCEN) (House) Action Alert regarding the Federal Reserves implementation of its FedNow (faster payments) Service (Federal Reserve) Action Alert regarding the National Credit Union Administration (NCUA) proposed rule about serving core-based/urban statistical areas (NCUA) Miscellaneous - Tax-exempt credit unions purchasing taxpaying community banks (House and Senate, OCC, CFPB) FDIC Listening Session on Supervisory Appeals and Dispute Resolution Process (FDIC) Closing the supervisory loophole for Industrial Loan Corporations (ILCs) (House)

H.R. 741, TAILOR Act H.R. 189, Financial Institution Customer Protection Act of 2019 H.R. 1595, the Secure and Fair Enforcement (SAFE) Banking Act of 2019 S. 1200, Secure and Fair Enforcement Banking (SAFE) Act of 2019 S. 1233, Community Bank Access to Capital Sec. 2821 of S. 1790, National Defense Authorization Act of 2020

Client expense: $2,161,000 · Firm income: Not reported

H.R. 388 Financial Reporting Threshold Modernization H.R. 442 Financial Protection for Our Military Families Act H.R. 578 The Cooperate with Law Enforcement and Watch Act H.R. 741 Tailor Act of 2019 H.R. 799 Federal Worker Credit Protection Act of 2019 H.R. 1038 Treasury Dept. to take greater role in Anti-Money Laundering/CFT policy and examinations H.R. 1039 Streamline Currency Transaction Reports and Suspicious Activity Reports H.R. 1285 Improving Access to Traditional Banking Act H.R. 1387 CONFRONT Act H.R. 1491 FINTECH Act of 2019 H.R. 1595 SAFE Banking Act H.R. 2513 Reforms collection of beneficial ownership information for corporations and LLCs H.R. 2514 Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act: Makes amendments to Bank Secrecy Act H.R. 3167 National Flood Insurance Program Reauthorization Act H.R. 3182 Requires agency study of Current Expected Credit Loss standard and delays effective date of standard H.R. 3198 Comprehensive Regulatory Review Act: Make changes to EGRPRA Review H.R. 3614 Restricting Use of Credit Checks for Employment Decisions Act H.R. 3618 Free Credit Scores for Consumers Act of 2019 H.R. 3621 Student Borrowers Credit Improvement Act H.R. 3622 Restoring Unfairly Impaired Credit and Protecting Consumers Act S. 331 Home Loan Quality Transparency Act S. 540 Self-Employed Mortgage Access Act S. 592 Cybersecurity Disclosure Act of 2019 S. 656 SAFE Lending Act of 2019 S. 1028 States Act S. 1200 SAFE Banking Act S. 1233 Community Bank Access to Capital Act: Raises exemption threshold for SOX 404(b) and reforms SEC Regulation S. 1564 Requires agency study of Current Expected Credit Loss standard and delays effective date of standard Bank Secrecy Act/Anti-Money Laundering Rules/Legislation, including Beneficial Ownership Issue Brokered Deposits/ National Interest Rate Caps Call Report Streamlining Cannabis Banking CFPB Small Business Loan Data Collection Community Bank Access to Capital Community Bank Leverage Ratio Community Development Financial Institutions (CDFI) Fund Appropriations Community Reinvestment Act Corporate Ownership Transparency Credit Union Business Lending Powers Credit Union Emergency Mergers Credit Union Field of Membership Rules Credit Union Growth/Powers/Abusive Behavior Credit Union Supplemental Capital Current Expected Credit Losses (CECL) Customer Due Diligence Rule Cybersecurity Data Security, Breaches and Privacy De Novo Bank Applications/Policy Deposit Concentration Cap Economic Growth, Regulatory Relief and Consumer Protection Act Implementation Examination Appeals Faster Payments/Federal Reserve Real Time Gross Settlement System Flood Insurance Reauthorization Home Mortgage Disclosure Act (HMDA) Regulations Housing Finance Reform Industrial Loan Corporation Loophole Reforms/ Square (ILC) Deposit Insurance Application Innovation Initiative (FinTech) Minority Depository Institutions Issues Nomination of Michelle Bowman for the Federal Reserve Board of Governors - For Full Term OCC Special Purpose Fintech Charter Postal Banking Private Flood Insurance Qualified Mortgages, Ability to Repay Rules Real-Time Gross Settlement (RTGS) service Regulatory Burden Relief for Community Banks Regulatory and Tax Relief for Community Banks Remittance Transfers