Calculate PPP Forgiveness Act of 2020

H.R. 748 CARES Act H.R. 925 Updated Heroes Act H.R. 6800 HEROES Act H.R. 6821 Small Business Expense Protection Act of 2020 H.R. 7010 Paycheck Protection Program Flexibility Act of 2020 H.R. 7413 Calculate PPP Forgiveness Act H.R. 7777 PPP Small Business Forgiveness Act H.R. 7894 Paycheck Protection Program Small Business Enhancement Act H.R. 8631 EIDL Forgiveness Act S. 3548 CARES Act S. 3612 Small Business Expense Protection Act of 2020 S. 4014 Prioritized Paycheck Protection Program Act S. 4116 Reauthorize lending under the payment protection program S. 4117 The Paycheck Protection Program Small Business Forgiveness Act S. 4171 Calculate PPP Forgiveness Act of 2020 CARES Act, Paycheck Protection Program Implementation PPP Forgiveness Process PPP Modifications to Program SBA 7(a) Program Funding and Terms SBA COVID-19 Lending Programs

Client expense: $840,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Emergency Management Agency (FEMA), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA), Treasury, Dept of, White House Office

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

Community Bankers Association of Illinois 2020 Federal Policy Priorities - Support The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) Support Additional Meaningful Regulatory Relief for Community Banks Oppose Credit Unions Expanded Powers Close the Industrial Loan Company (ILC) Regulatory Loophole Oppose Farm Credit Systems Expanded Powers Support the Federal Reserves Role in Payments System Improvement Support Modernizing the Community Reinvestment Act (CRA) Modify the FDICs Brokered Deposit Rule Support Safe Harbor for Banking Cannabis-Related Businesses Support De Novo Community Bank Formation, the Dual Banking System and Charter Choice Support Sound Principles for GSE Reform Support the Federal Home Loan Banks Support Agriculture and Rural America Support Enhanced Data, Cyber and Payment Card Security (Data Security) Support Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Support the Community Bank Positions on Emerging Issues OCCs Special Purpose Fintech National Bank (SPNBs) Fintech Charters FASBs Current Expected Credit Loss Model CFPBs Customer Data Sharing CFPBs Small-Dollar Consumer Lending CFPB's Small Business Data Collection Federal Reserves Modernize Reg CC Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts (House, Senate, CFPB, OCC, FDIC, Federal Reserve, FHFA) Legislation and Regulation - S. 4117 - Paycheck Protection Small Business Forgiveness Act (All Sections) Regarding Paycheck Protection Program (PPP) loans of $150,000 and under qualifying for forgiveness with one-page application (Senate) H.R. 7777 - Paycheck Protection Small Business Forgiveness Act (All Sections) Regarding Paycheck Protection Program (PPP) loans of $150,000 and under provided automatic forgiveness (House) Closing the Industrial Loan Company (ILC) loophole - discussion draft of legislation (House) Closing the Industrial Loan Company (ILC) loophole - Wirecard AG and Wirecard Bank in Germany and similarities with U.S. ILCs and their holding companies (House) Community Bank top priorities for pandemic relief measures - 1) Cosponsor legislation in the Senate and House (S. 4117 and H.R. 7777), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less; 2) Allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses. (S. 3612/H.R. 6821); 3) Support local regions by raising the current bank-qualified municipal bond annual issuance limit to $50 million from $10 million to expedite low-cost funding for local projects; 4) Enact bank capital and accounting relief measures to support borrowers and lenders facing historically challenging circumstances by extending Troubled Debt Restructuring (TDR), suspending the Current Expected Credit Loss (CECL) requirements, and making the 8% Community Bank Leverage Ratio (CBLR) permanent for institutions of $10 billion or less in assets; 5) Create capacity for additional lending by requiring SBA to purchase PPP loan at par; 6) Create a liability safe harbor for businesses from COVID-19-related lawsuits; 7) Support rural America by allowing interest on loans secured by agricultural real estate or primary residences in rural communities to be tax-exempt (ECORA, S. 1641/H.R. 1872), providing direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhance USDA guaranteed lending programs; 8) Expand the Employee Retention Tax Credit (ERTC) created by the CARES Act (H.R. 6776); 9) Enact an Industrial Loan Company moratorium of at least three years on the FDICs approval of deposit insurance applications. (A three-year moratorium was included in the Dodd-Frank Act as an appropriate response to a highly uncertain economic environment); 10) Extend the QM patch to January 2022 to help avoid additional disruption to the housing market. (House and Senate) Second Initiative - Community Bank top priorities for pandemic relief measures - 1) Support Sen. Cramers legislation (S. 4117), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less-allowing business owners to focus on their businesses and the safety of their employees and customers (protections against fraud and misrepresentation still apply). 2) Support Sen. Kings legislation (S. 4171), which would require Treasury or SBA (not a third-party) to create an easy-to-use online loan forgiveness calculator to help clear up what is a very confusing and complex application process. This would ensure borrowers and lenders protection and accuracy. 3) Support Rep. Houlahans legislation (H.R. 7777), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less-allowing business owners to focus on their businesses and the safety of their employees and customers (protections against fraud and misrepresentation still apply). 4) Support Rep. Wagners legislation (H.R. 7413), which would require Treasury or SBA (not a third-party) to create an easy-to-use online loan forgiveness calculator to help clear up what is a very confusing and complex application process. This would ensure borrowers and lenders protection and accuracy. 5) Create capacity for additional lending by requiring SBA to purchase PPP loans at par (minus the amount that has been forgiven). 6) Ensure PPP loans are not included in regulatory asset threshold calculations. If PPP lending causes our assets to exceed certain thresholds, additional regulations and supervision are triggered, causing many community banks to face costly, burdensome and unintended consequences. 7) Support Sen. Cornyns legislation (S. 3612), which would allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses, as they ordinarily would. Without this, the value of a PPP loan is effectively reduced and tax preparation is unnecessarily cumbersome. 8) Support Rep. Holdings legislation (H.R. 6821), which would allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses, as they ordinarily would. Without this, the value of a PPP loan is effectively reduced and tax preparation is unnecessarily cumbersome. 9) Enact bank capital and accounting relief measures to support borrowers and lenders facing historically challenging circumstances by extending TDR, suspending CECL and making the 8% CBLR permanent for institutions of $10 billion or less in assets. Banks strong capitalization at the beginning of the crisis means that capital and accounting could be implemented without compromising safety and soundness. 10) Create a liability safe harbor for businesses from COVID-19-related lawsuits. Community banks and small businesses have every incentive to ensure the personal safety of their employees and customers. Fear of opportunistic class actions or other suits will inhibit the restoration of economic activity. 11) Support rural America by passing Rep. Watkinss ECORA Act (H.R. 1872), which exempts interest on most agricultural loans from taxable income (lowering interest rates for farmers, ranchers and rural homeowners), provides direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhances USDA guaranteed lending programs. (House, Senate) FHFA/Fannie/Freddie .50% residential mortgage guarantee fee increase with a September 1, 2020 implementation date (FHFA, Federal Reserve, OCC, House, Senate) S. 2939 - Eliminating Corporate Shadow Banking Act of 2019 (all Sections) Regarding closing the Industrial Loan Company loophole - consolidated holding company supervision by the Federal Reserve (Senate) Revised FDIC Guidelines for Appeals of Material Supervisory Determinations (FDIC) Letters - Comment Letter to the Federal Deposit Insurance Corporation (FDIC) regarding: Proposed Rule - Parent Companies of Industrial Banks and Industrial Loan Companies; RIN 3064-AF31 (FDIC, House, Federal Reserve) Addendum to Comment Letter to the Federal Deposit Insurance Corporation (FDIC) regarding: Proposed Rule - Parent Companies of Industrial Banks and Industrial Loan Companies; RIN 3064-AF31 (FDIC, House, Federal Reserve) Comment Letter to the National Credit Union Administration (NCUA) regarding: Subordinated Debt; Proposed Rule RIN 3133-AF08 (NCUA) Comment Letter to the Consumer Financial Protection Bureau (CFPB) regarding: Request for Information on Equal Credit Opportunity and Regulation B; Docket No CFPB-2020-0026 (CFPB) Action Alerts - Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate) Action Alert regarding FHFA/Fannie/Freddie .50% residential mortgage guarantee fee increase with a September 1, 2020 implementation date (House, Senate) #2 Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate) Miscellaneous - OCC proposal to issue payments charters (OCC) Beneficial ownership reporting regulatory relief (with FinCEN - not a community bank responsibility) (House) Postal Service financial services [banking] pilot program (House) Community Reinvestment Act (CRA) modernization (joint rulemaking) (House) Payments System Improvements (Federal Reserve FedNow Service) (House) FinCEN breach of information on Suspicious Activity Reports (SARs) (FDIC) Expiration of time to receive, and delivery of, Economic Impact Payments (EIPs) (House, Senate)

Community Bankers Association of Illinois 2020 Federal Policy Priorities - Support The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) Support Additional Meaningful Regulatory Relief for Community Banks Oppose Credit Unions Expanded Powers Close the Industrial Loan Company (ILC) Regulatory Loophole Oppose Farm Credit Systems Expanded Powers Support the Federal Reserves Role in Payments System Improvement Support Modernizing the Community Reinvestment Act (CRA) Modify the FDICs Brokered Deposit Rule Support Safe Harbor for Banking Cannabis-Related Businesses Support De Novo Community Bank Formation, the Dual Banking System and Charter Choice Support Sound Principles for GSE Reform Support the Federal Home Loan Banks Support Agriculture and Rural America Support Enhanced Data, Cyber and Payment Card Security (Data Security) Support Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Support the Community Bank Positions on Emerging Issues OCCs Special Purpose Fintech National Bank (SPNBs) Fintech Charters FASBs Current Expected Credit Loss Model CFPBs Customer Data Sharing CFPBs Small-Dollar Consumer Lending CFPB's Small Business Data Collection Federal Reserves Modernize Reg CC Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts (House, Senate, CFPB, OCC, FDIC, Federal Reserve, FHFA) Legislation and Regulation - S. 4117 - Paycheck Protection Small Business Forgiveness Act (All Sections) Regarding Paycheck Protection Program (PPP) loans of $150,000 and under qualifying for forgiveness with one-page application (Senate) H.R. 7777 - Paycheck Protection Small Business Forgiveness Act (All Sections) Regarding Paycheck Protection Program (PPP) loans of $150,000 and under provided automatic forgiveness (House) Closing the Industrial Loan Company (ILC) loophole - discussion draft of legislation (House) Closing the Industrial Loan Company (ILC) loophole - Wirecard AG and Wirecard Bank in Germany and similarities with U.S. ILCs and their holding companies (House) Community Bank top priorities for pandemic relief measures - 1) Cosponsor legislation in the Senate and House (S. 4117 and H.R. 7777), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less; 2) Allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses. (S. 3612/H.R. 6821); 3) Support local regions by raising the current bank-qualified municipal bond annual issuance limit to $50 million from $10 million to expedite low-cost funding for local projects; 4) Enact bank capital and accounting relief measures to support borrowers and lenders facing historically challenging circumstances by extending Troubled Debt Restructuring (TDR), suspending the Current Expected Credit Loss (CECL) requirements, and making the 8% Community Bank Leverage Ratio (CBLR) permanent for institutions of $10 billion or less in assets; 5) Create capacity for additional lending by requiring SBA to purchase PPP loan at par; 6) Create a liability safe harbor for businesses from COVID-19-related lawsuits; 7) Support rural America by allowing interest on loans secured by agricultural real estate or primary residences in rural communities to be tax-exempt (ECORA, S. 1641/H.R. 1872), providing direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhance USDA guaranteed lending programs; 8) Expand the Employee Retention Tax Credit (ERTC) created by the CARES Act (H.R. 6776); 9) Enact an Industrial Loan Company moratorium of at least three years on the FDICs approval of deposit insurance applications. (A three-year moratorium was included in the Dodd-Frank Act as an appropriate response to a highly uncertain economic environment); 10) Extend the QM patch to January 2022 to help avoid additional disruption to the housing market. (House and Senate) Second Initiative - Community Bank top priorities for pandemic relief measures - 1) Support Sen. Cramers legislation (S. 4117), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less-allowing business owners to focus on their businesses and the safety of their employees and customers (protections against fraud and misrepresentation still apply). 2) Support Sen. Kings legislation (S. 4171), which would require Treasury or SBA (not a third-party) to create an easy-to-use online loan forgiveness calculator to help clear up what is a very confusing and complex application process. This would ensure borrowers and lenders protection and accuracy. 3) Support Rep. Houlahans legislation (H.R. 7777), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less-allowing business owners to focus on their businesses and the safety of their employees and customers (protections against fraud and misrepresentation still apply). 4) Support Rep. Wagners legislation (H.R. 7413), which would require Treasury or SBA (not a third-party) to create an easy-to-use online loan forgiveness calculator to help clear up what is a very confusing and complex application process. This would ensure borrowers and lenders protection and accuracy. 5) Create capacity for additional lending by requiring SBA to purchase PPP loans at par (minus the amount that has been forgiven). 6) Ensure PPP loans are not included in regulatory asset threshold calculations. If PPP lending causes our assets to exceed certain thresholds, additional regulations and supervision are triggered, causing many community banks to face costly, burdensome and unintended consequences. 7) Support Sen. Cornyns legislation (S. 3612), which would allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses, as they ordinarily would. Without this, the value of a PPP loan is effectively reduced and tax preparation is unnecessarily cumbersome. 8) Support Rep. Holdings legislation (H.R. 6821), which would allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses, as they ordinarily would. Without this, the value of a PPP loan is effectively reduced and tax preparation is unnecessarily cumbersome. 9) Enact bank capital and accounting relief measures to support borrowers and lenders facing historically challenging circumstances by extending TDR, suspending CECL and making the 8% CBLR permanent for institutions of $10 billion or less in assets. Banks strong capitalization at the beginning of the crisis means that capital and accounting could be implemented without compromising safety and soundness. 10) Create a liability safe harbor for businesses from COVID-19-related lawsuits. Community banks and small businesses have every incentive to ensure the personal safety of their employees and customers. Fear of opportunistic class actions or other suits will inhibit the restoration of economic activity. 11) Support rural America by passing Rep. Watkinss ECORA Act (H.R. 1872), which exempts interest on most agricultural loans from taxable income (lowering interest rates for farmers, ranchers and rural homeowners), provides direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhances USDA guaranteed lending programs. (House, Senate) FHFA/Fannie/Freddie .50% residential mortgage guarantee fee increase with a September 1, 2020 implementation date (FHFA, Federal Reserve, OCC, House, Senate) S. 2939 - Eliminating Corporate Shadow Banking Act of 2019 (all Sections) Regarding closing the Industrial Loan Company loophole - consolidated holding company supervision by the Federal Reserve (Senate) Revised FDIC Guidelines for Appeals of Material Supervisory Determinations (FDIC) Letters - Comment Letter to the Federal Deposit Insurance Corporation (FDIC) regarding: Proposed Rule - Parent Companies of Industrial Banks and Industrial Loan Companies; RIN 3064-AF31 (FDIC, House, Federal Reserve) Addendum to Comment Letter to the Federal Deposit Insurance Corporation (FDIC) regarding: Proposed Rule - Parent Companies of Industrial Banks and Industrial Loan Companies; RIN 3064-AF31 (FDIC, House, Federal Reserve) Comment Letter to the National Credit Union Administration (NCUA) regarding: Subordinated Debt; Proposed Rule RIN 3133-AF08 (NCUA) Comment Letter to the Consumer Financial Protection Bureau (CFPB) regarding: Request for Information on Equal Credit Opportunity and Regulation B; Docket No CFPB-2020-0026 (CFPB) Action Alerts - Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate) Action Alert regarding FHFA/Fannie/Freddie .50% residential mortgage guarantee fee increase with a September 1, 2020 implementation date (House, Senate) #2 Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate) Miscellaneous - OCC proposal to issue payments charters (OCC) Beneficial ownership reporting regulatory relief (with FinCEN - not a community bank responsibility) (House) Postal Service financial services [banking] pilot program (House) Community Reinvestment Act (CRA) modernization (joint rulemaking) (House) Payments System Improvements (Federal Reserve FedNow Service) (House) FinCEN breach of information on Suspicious Activity Reports (SARs) (FDIC) Expiration of time to receive, and delivery of, Economic Impact Payments (EIPs) (House, Senate)

Community Bankers Association of Illinois 2020 Federal Policy Priorities - Support The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) Support Additional Meaningful Regulatory Relief for Community Banks Oppose Credit Unions Expanded Powers Oppose Farm Credit Systems Expanded Powers Support the Federal Reserves Role in Payments System Improvement Support Modernizing the Community Reinvestment Act (CRA) Support Safe Harbor for Banking Cannabis-Related Businesses Support Agriculture and Rural America Support Enhanced Data, Cyber and Payment Card Security (Data Security) Support Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Support the Community Bank Positions on Emerging Issues CFPBs Customer Data Sharing CFPBs Small Business Data Collection Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts (House, Senate, CFPB, OCC, FDIC, Federal Reserve, FHFA) Legislation and Regulation - S. 4117 - Paycheck Protection Small Business Forgiveness Act (All Sections) Regarding Paycheck Protection Program (PPP) loans of $150,000 and under qualifying for forgiveness with one-page application (Senate) H.R. 7777 - Paycheck Protection Small Business Forgiveness Act (All Sections) Regarding Paycheck Protection Program (PPP) loans of $150,000 and under provided automatic forgiveness (House) Community Bank top priorities for pandemic relief measures - 1) Cosponsor legislation in the Senate and House (S. 4117 and H.R. 7777), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less; 2) Allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses. (S. 3612/H.R. 6821); 3) Enact bank capital and accounting relief measures to support borrowers and lenders facing historically challenging circumstances by extending Troubled Debt Restructuring (TDR), suspending the Current Expected Credit Loss (CECL) requirements, and making the 8% Community Bank Leverage Ratio (CBLR) permanent for institutions of $10 billion or less in assets; 4) Create capacity for additional lending by requiring SBA to purchase PPP loan at par; 5) Create a liability safe harbor for businesses from COVID-19-related lawsuits; 6) Support rural America by allowing interest on loans secured by agricultural real estate or primary residences in rural communities to be tax-exempt (ECORA, S.1641/H.R. 1872), providing direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhance USDA guaranteed lending programs; 7) Expand the Employee Retention Tax Credit (ERTC) created by the CARES Act (H.R. 6776) (House and Senate) Second Initiative - Community Bank top priorities for pandemic relief measures - 1) Support Sen. Cramers legislation (S. 4117), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less-allowing business owners to focus on their businesses and the safety of their employees and customers (protections against fraud and misrepresentation still apply). 2) Support Sen. Kings legislation (S. 4171), which would require Treasury or SBA (not a third-party) to create an easy-to-use online loan forgiveness calculator to help clear up what is a very confusing and complex application process. This would ensure borrowers and lenders protection and accuracy. 3) Support Rep. Houlahans legislation (H.R. 7777), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less-allowing business owners to focus on their businesses and the safety of their employees and customers (protections against fraud and misrepresentation still apply). 4) Support Rep. Wagners legislation (H.R. 7413), which would require Treasury or SBA (not a third-party) to create an easy-to-use online loan forgiveness calculator to help clear up what is a very confusing and complex application process. This would ensure borrowers and lenders protection and accuracy. 5) Create capacity for additional lending by requiring SBA to purchase PPP loans at par (minus the amount that has been forgiven). 6) Ensure PPP loans are not included in regulatory asset threshold calculations. If PPP lending causes our assets to exceed certain thresholds, additional regulations and supervision are triggered, causing many community banks to face costly, burdensome and unintended consequences. 7) Support Sen. Cornyns legislation (S. 3612), which would allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses, as they ordinarily would. Without this, the value of a PPP loan is effectively reduced and tax preparation is unnecessarily cumbersome. 8) Support Rep. Holdings legislation (H.R. 6821), which would allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses, as they ordinarily would. Without this, the value of a PPP loan is effectively reduced and tax preparation is unnecessarily cumbersome. 9) Enact bank capital and accounting relief measures to support borrowers and lenders facing historically challenging circumstances by extending TDR, suspending CECL and making the 8% CBLR permanent for institutions of $10 billion or less in assets. Banks strong capitalization at the beginning of the crisis means that capital and accounting could be implemented without compromising safety and soundness. 10) Create a liability safe harbor for businesses from COVID-19-related lawsuits. Community banks and small businesses have every incentive to ensure the personal safety of their employees and customers. Fear of opportunistic class actions or other suits will inhibit the restoration of economic activity. 11) Support rural America by passing Rep. Watkinss ECORA Act (H.R. 1872), which exempts interest on most agricultural loans from taxable income (lowering interest rates for farmers, ranchers and rural homeowners), provides direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhances USDA guaranteed lending programs. (House, Senate) Letters - Comment Letter to the National Credit Union Administration (NCUA) regarding: Subordinated Debt; Proposed Rule RIN 3133-AF08 (NCUA) Comment Letter to the Consumer Financial Protection Bureau (CFPB) regarding: Request for Information on Equal Credit Opportunity and Regulation B; Docket No CFPB-2020-0026 (CFPB) Action Alerts - Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate) #2 Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate) Miscellaneous - OCC proposal to issue payments charters (OCC) Beneficial ownership reporting regulatory relief (with FinCEN - not a community bank responsibility) (House) Postal Service financial services [banking] pilot program (House) Community Reinvestment Act (CRA) modernization (joint rulemaking) (House) Payments System Improvements (Federal Reserve FedNow Service) (House)

Community Bankers Association of Illinois 2020 Federal Policy Priorities - Support The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) Support Additional Meaningful Regulatory Relief for Community Banks Oppose Credit Unions Expanded Powers Oppose Farm Credit Systems Expanded Powers Support the Federal Reserves Role in Payments System Improvement Support Modernizing the Community Reinvestment Act (CRA) Support Safe Harbor for Banking Cannabis-Related Businesses Support Sound Principles for GSE Reform Support the Federal Home Loan Banks Support Agriculture and Rural America Support Enhanced Data, Cyber and Payment Card Security (Data Security) Support the Community Bank Positions on Emerging Issues CFPBs Customer Data Sharing CFPB's Small Business Data Collection Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts (House, Senate, CFPB, OCC, FDIC, Federal Reserve, FHFA) Legislation and Regulation - S. 4117 - Paycheck Protection Small Business Forgiveness Act (All Sections) Regarding Paycheck Protection Program (PPP) loans of $150,000 and under qualifying for forgiveness with one-page application (Senate) H.R. 7777 - Paycheck Protection Small Business Forgiveness Act (All Sections) Regarding Paycheck Protection Program (PPP) loans of $150,000 and under provided automatic forgiveness (House) Community Bank top priorities for pandemic relief measures - 1) Cosponsor legislation in the Senate and House (S. 4117 and H.R. 7777), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less; 2) Allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses. (S. 3612/H.R. 6821); 3) Support local regions by raising the current bank-qualified municipal bond annual issuance limit to $50 million from $10 million to expedite low-cost funding for local projects; 4) Enact bank capital and accounting relief measures to support borrowers and lenders facing historically challenging circumstances by extending Troubled Debt Restructuring (TDR), suspending the Current Expected Credit Loss (CECL) requirements, and making the 8% Community Bank Leverage Ratio (CBLR) permanent for institutions of $10 billion or less in assets; 5) Create capacity for additional lending by requiring SBA to purchase PPP loan at par; 6) Create a liability safe harbor for businesses from COVID-19-related lawsuits; 7) Support rural America by allowing interest on loans secured by agricultural real estate or primary residences in rural communities to be tax-exempt (ECORA, S. 1641/H.R. 1872), providing direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhance USDA guaranteed lending programs; 8) Expand the Employee Retention Tax Credit (ERTC) created by the CARES Act (H.R. 6776), 9) Extend the QM patch to January 2022 to help avoid additional disruption to the housing market. (House and Senate) Second Initiative - Community Bank top priorities for pandemic relief measures - 1) Support Sen. Cramers legislation (S. 4117), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less-allowing business owners to focus on their businesses and the safety of their employees and customers (protections against fraud and misrepresentation still apply). 2) Support Sen. Kings legislation (S. 4171), which would require Treasury or SBA (not a third-party) to create an easy-to-use online loan forgiveness calculator to help clear up what is a very confusing and complex application process. This would ensure borrowers and lenders protection and accuracy. 3) Support Rep. Houlahans legislation (H.R. 7777), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less-allowing business owners to focus on their businesses and the safety of their employees and customers (protections against fraud and misrepresentation still apply). 4) Support Rep. Wagners legislation (H.R. 7413), which would require Treasury or SBA (not a third-party) to create an easy-to-use online loan forgiveness calculator to help clear up what is a very confusing and complex application process. This would ensure borrowers and lenders protection and accuracy. 5) Create capacity for additional lending by requiring SBA to purchase PPP loans at par (minus the amount that has been forgiven). 6) Ensure PPP loans are not included in regulatory asset threshold calculations. If PPP lending causes our assets to exceed certain thresholds, additional regulations and supervision are triggered, causing many community banks to face costly, burdensome and unintended consequences. 7) Support Sen. Cornyns legislation (S. 3612), which would allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses, as they ordinarily would. Without this, the value of a PPP loan is effectively reduced and tax preparation is unnecessarily cumbersome. 8) Support Rep. Holdings legislation (H.R. 6821), which would allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses, as they ordinarily would. Without this, the value of a PPP loan is effectively reduced and tax preparation is unnecessarily cumbersome. 9) Enact bank capital and accounting relief measures to support borrowers and lenders facing historically challenging circumstances by extending TDR, suspending CECL and making the 8% CBLR permanent for institutions of $10 billion or less in assets. Banks strong capitalization at the beginning of the crisis means that capital and accounting could be implemented without compromising safety and soundness. 10) Create a liability safe harbor for businesses from COVID-19-related lawsuits. Community banks and small businesses have every incentive to ensure the personal safety of their employees and customers. Fear of opportunistic class actions or other suits will inhibit the restoration of economic activity. 11) Support rural America by passing Rep. Watkinss ECORA Act (H.R. 1872), which exempts interest on most agricultural loans from taxable income (lowering interest rates for farmers, ranchers and rural homeowners), provides direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhances USDA guaranteed lending programs. (House, Senate) Letters - Comment Letter to the National Credit Union Administration (NCUA) regarding: Subordinated Debt; Proposed Rule RIN 3133-AF08 (NCUA) Comment Letter to the Consumer Financial Protection Bureau (CFPB) regarding: Request for Information on Equal Credit Opportunity and Regulation B; Docket No CFPB-2020-0026 (CFPB) Action Alerts - Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate) #2 Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate) Miscellaneous - OCC proposal to issue payments charters (OCC) Beneficial ownership reporting regulatory relief (with FinCEN - not a community bank responsibility) (House) Postal Service financial services [banking] pilot program (House) Community Reinvestment Act (CRA) modernization (joint rulemaking) (House) Payments System Improvements (Federal Reserve FedNow Service) (House)

H.R. 748 CARES Act 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 S. 3548 CARES Act S. 3612 Small Business Expense Protection Act of 2020 S. 4014 Prioritized Paycheck Protection Program Act S. 4116 Reauthorize lending under the payment protection program S. 4117 The Paycheck Protection Program Small Business Forgiveness Act S. 4171 Calculate PPP Forgiveness Act of 2020 CARES Act, Paycheck Protection Program Implementation PPP Forgiveness Process PPP Modifications to Program SBA 7(a) Program Funding and Terms SBA COVID-19 Lending Programs

Client expense: $850,000 · 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. 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