Veterans and Consumers Fair Credit Act

Issues pertaining to S. 2508 and H.R. 5974, Veterans and Consumers Fair Credit Act.

Client expense: $210,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

While MCUL takes no position on the issue of cannabis legalization, it supports legislation in the 117th Congress that would provide a safe harbor for financial institutions to serve their members needs in states where cannabis use has become legal. MCUL supports the SAFE Banking Act of 2021, S. 910 and H.R. 1996 which would provide a safe harbor for credit unions and other financial institutions. MCUL stands opposed to efforts to change the existing interchange system by expanding requirements under the so-called Durbin Amendment established under the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. We have been educating our delegation on the importance of the current credit card interchange system with regard to ensuring consumer data remains secure and private and are asking our delegation to oppose S. 4674/H.R. 8874, the Credit Card Competition Act of 2022 because of the harm it would do to credit unions, their members, along with other financial institutions and their customers. We continue to educate our congressional delegation on voluntary overdraft protection services offered by credit unions and the value our members place on these services. MCUL is opposed to legislation (H.R. 4277 and S. 2677) that would severely limit a financial institutions ability to offer these voluntary services to our members. MCUL supports and is calling for passage of H.R. 3962 and S.1625, the SECURE Notarization Act that would establish minimum standards for electronic and remote notarization. We are also educating our delegation on the importance of updating the 20 year old E-sign Act to better reflect how customers can signal their acceptance of electronic transactions. MCUL is opposed to S. 2508, the Veteran's and Consumer Fair Credit Act that would extend provisions of the Military Lending Act (MLA), which establishes a 36% all-in rate cap on most loans to service members, to all consumer loans. The all-in cap would make it very difficult for credit unions to maintain viable small-dollar programs and severely hinder a state credit union's ability to offer overdraft products.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Federal policy relating to anticipated Consumer Financial Protection Bureau regulation of consumer financial services including payday lending, auto title lending, and regulatory process. Potential legislation to regulate interest rates on financial products. S.J. Res. 15 - A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders." Implementation of the CARES Act (PL 116-136), provisions relating to the payroll protection program. Implementation of the American Rescue Plan Act of 2021 (PL-117-2), provisions relating to the payroll protection program. Legislative proposals relating to prohibiting retail businesses from refusing cash payments. H.R. 2040, The Financial Reporting Threshold Modernization Act, provisions relating to updating thresholds for certain currency transaction reports and suspicious activity reports. H.R. 1996, The SAFE Banking Act of 2021, provisions relating to the provision of financial services to cannabis-related businesses and service providers S. 563, The Fair Access to Banking Act, provisions relating to fair access to financial services and discount window lending programs. Veterans and Consumers Fair Credit Act (H.R. 5974/S. 2508), provisions relating to regulation of interest rates on financial products.

Client expense: Not reported · Firm income: $50,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

All legislation related to consumer lending regulation and consumer lending policy. S. 2349, the Protecting Consumers from Unreasonable Credit Rates Act of 2021. S. 2508, the Veterans and Consumers Fair Credit Act of 2021. H.R. 5974, Veterans and Consumers Fair Credit Act.

Client expense: Not reported · Firm income: $70,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 935/S. 3391, Small Business Mergers, Acquisitions, Sales, and Brokerage Simplification Act of 2021 H.R. 1087, Shareholder Political Transparency Act of 2021 H.R. 1187, Corporate Governance Improvement and Investor Protection Act H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 1602, Eliminate Barriers to Innovation Act of 2021 H.R. 2025/S. 840, To amend title 28, United States Code, to increase transparency and oversight of third-party litigation funding in certain actions, and for other purposes H.R. 2516, Promoting Diversity and Inclusion in Banking Act of 2021 H.R. 2543, Federal Reserve Racial and Economic Equity Act H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2570, Climate Risk Disclosure Act of 2021 H.R. 2620, Investor Choice Act of 2021 H.R. 2990/S. 3931, Gig Worker Equity Compensation Act H.R. 3007, Disclosure of Tax Havens and Offshoring Act H.R. 3448/S. 4992, Helping Startups Continue to Grow Act H.R. 3454, Modernizing Disclosures for Investors Act H.R. 3843, Merger Filing Fee Modernization Act of 2022 H.R. 4227/S. 3914, Developing and Empowering our Aspiring Leaders Act H.R. 4277, Overdraft Protection Act of 2021 H.R. 4345, Financial Services and General Government Appropriations Act, 2022 H.R. 4521, America Creating Opportunities for Manufacturing, Pre-Eminence in Technology, and Economic Strength (America COMPETES) Act of 2022, including provisions related to House Amendment 218 H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate (LIBOR) Act of 2021 H.R. 4773, Consumer Financial Protection Commission Act H.R. 5128/S. 3503, Expanding Access to Capital for Rural Job Creators Act H.R. 5525, Establishing New Authorities for Businesses Laundering and Enabling Risks to Security (ENABLERS) Act H.R. 5586/S. 3056, Prohibiting IRS Financial Surveillance Act H.R. 5598/S. 3961, Access to Small Business Investor Capital Act H.R. 5648/S. 3022, Stop Wall Street Looting Act H.R. 5795/S. 3097, Main Street Growth Act H.R. 5910, Holding SPACs Accountable Act of 2021 H.R. 5911, Fair Hiring in Banking Act H.R. 7151, Ensuring Sound Guidance Act H.R. 7900, National Defense Authorization Act for Fiscal Year 2023 H.R. 7977, Promoting Opportunities for Non-Traditional Capital Formation Act H.R. 8254/S. 4685, Financial Services and General Government Appropriations Act, 2023 H.R. 8521, Investor Democracy is Expected (INDEX) Act S. 479, Lifting Our Communities through Advance Liquidity for (LOCAL) Infrastructure Act S. 2417, Credit Access and Inclusion Act of 2021 S. 2508, Veterans and Consumers Fair Credit Act S. 3410, The Consumer Protection and Due Process Act S. 3755, Arbitration Fairness for Consumers Act S. 3921, Equal Opportunity for all Investors Act S. 3923, Dodd-Frank Material Disclosure Improvement Act S. 3930, Administrative Enforcement Fairness Act of 2022 S. 3939, Small Entrepreneurs' Empowerment and Development (SEED) Act of 2022 S. 3967, Improving Crowdfunding Opportunities Act S. 3976, Expanding American Entrepreneurship Act S. 4241, Investor Democracy is Expected (INDEX) Act S. 5005, Mandatory Materiality Requirement Act of 2022 Draft legislation titled Jumpstart our Business Startups (JOBS) Act 4.0 of 2022 Draft legislation titled Mandatory Materiality Requirement Act of 2022 Potential legislation to foster economic growth and job creation through capital formation Potential legislation to further economic growth through environmental, social, and governance factors Potential legislation to make changes to the Exchange Act Rule 14a-8 shareholder proposal process Potential legislation to hold proxy voting advice businesses accountable Potential legislation to require the SEC to consider additional standards in the rulemaking process Potential legislation to study the term small entity Potential legislation regarding a new regulatory framework for stablecoins Potential legislation dealing with third party litigation financing and lawsuit lending SEC Money Market Fund Reforms (86 Fed. Reg. 7,248, December 15, 2021) Proposed Rule, Securities and Exchange Commission; Prohibition Against Fraud, Manipulation, or Deception in Connection with Security-Based Swaps, Prohibition against Undue Influence over Chief Compliance Officers, Position Reporting of Large Security-Based Swap Positions (87 Fed. Reg. 6,652-6,706, February 4, 2022) Proposed rule on Enhancement and Standardization of Climate-Related Disclosures for Investors (87 Fed. Reg. 21,334-21,473, April 11,2022) Proposed Rule, Securities and Exchange Commission; Enhanced Disclosures by Certain Investment Advisers and Investment Companies About Environmental, Social, and Governance Investment Practices (87 Fed. Reg. 36,654-36,761, June 17, 2022) Proposed Rule, Securities and Exchange Commission; Investment Company Names (87 Fed. Reg. 36,594-36,651, June 17,2022) Request for Comment on Certain Information Providers Acting as Investment Advisers; Securities and Exchange Commission (87 Fed. Reg. 37,254-37,262, June 22, 2022) Request for Comment, Bureau of Consumer Financial Protection; Agency Information Collection Activities, Report of Terms of Credit Card Plans (Form FR 2572) and Consumer and College Credit Card Agreements (87 Fed. Reg. 50,851-50,852, August 18, 2022) Proposed Rule, Commodity Futures Trading Commission and Securities and Exchange Commission; Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers (87 Fed. Reg. 53,832-53,985 , September 1, 2022) Proposed Rule, Securities and Exchange Commission; Resubmission of Comments and Reopening of Comment Periods for Several Rulemaking Releases Due to a Technological Error is Receiving Certain Comments (87 Fed. Reg. 63,016-63,017, October 18, 2022) SEC Proposed Rule on ESG Disclosures for Investment Advisers and Investment Companies (87 Fed. Reg. 36,654 - 36,761, August 16, 2022) Request for Comment, Securities and Exchange Commission; Draft 2022-2026 Strategic Plan for Securities and Exchange Commission (87 Fed. Reg. 53,040, August 30, 2022) Request for Information, Commodity Futures Trading Commission; Climate-Related Financial Risk (87 Fed. Reg. 34,856-34,862, June 8, 2022) Various issues relating to SEC Best Interest and Enhancing Investment Adviser Regulation relating to broker-dealers, registered investment advisers, conflicts of interest; potential federal preemption of state fiduciary standards; Public Company Accounting Oversight Board (PCAOB); CFTCs de minimis Exception for Swap Dealers; Securities and Exchange Commission amendments to the Commissioners whistleblower rules file no. S7-16-18; proxy process, proxy advisory firms, and other related aspects of corporate governance; corporate common ownership; adoption of the current expected credit loss (CECL) accounting standard; role of credit reporting agencies (CRAs) in the U.S. economy; debt collection practices (regulation F) under the Fair Debt Collection Practices Act (P.L. 95-109); qualified mortgage definition under the Truth in Lending Act (P.L. 90-321) (Regulation Z); Financial Stability Oversight Council and the designation of Nonbank Financial Firms as systemically important; Federal Reserve Systems Large Institution Supervision Coordinating Committee; potential housing finance reform legislation; enforcement of Securities and Exchange Commission penalties; potential repeal of the State and Local Tax (SALT) Cap; federal interest rate authority; Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) reform; electronic consent-based SSN Verification Service (eCBSV); environmental, social, and governance (ESG) enforcement; information Collection under the Community Reinvestment Act (CRA); potential Financial Transaction Tax (FTT); potential Treasury Department proposal relating to tax reporting by banks; investment company cross trading; potential money market fund reform measures; resolutions to establish task forces on Artificial Intelligence and Financial Technology in the House Committee on Financial Services; transition to the secured overnight financing rate; implementation of SEC Rule 15c2-11; Department of Labor fiduciary advice exemption: PTE 2020-02; benefits of risk-based pricing; mobile disclosures; Federal Trade Commission issues: Freedom of Information Act Requests, Penalty Offense Authority, Zombie Voting, and overall direction of the Commission under Chair Lina Khan; Tax Reporting Proposal by the Department of the Treasury related to a $600 or more annual account threshold; Amendment to the FY22 National Defense Authorization Act related to credit reporting; Climate-Related Financial Risk Management for Large Banks; House Committee on Financial Services request for information related to Russia sanctions; Consumer Financial Protection Bureau (CFPB) regulatory sandbox for disclosures; CFPB Policy Fellowship program; CFPB amendment of its Supervision and Examination Manual; CFPB conflation of Distinct Statutory Concepts of Unfairness and Discrimination Promoting the importance of appropriate length of SEC Comment Periods; Internal Revenue Service; Priority Guidance Plan; Compliance Assistance Release, Department of Labor; 401(k) Plan Investments in Cryptocurrencies Request for Information, Consumer Financial Protection Bureau; Fees Imposed by Providers of Consumer Financial Products or Services; Notice of Inquiry, Federal Communications Commission; In the Matter of Implementing the Infrastructure Investment and Jobs Act: Prevention and Elimination of Digital Discrimination; (GN Docket No. 22-69); Consumer Financial Protection Bureau; Enhancing Public Data on Auto Lending; Document ID CFPB-2022-0075-0001 (November 17, 2022); Proposed Rule, Securities and Exchange Commission; Open-End Fund Liquidity Risk Management Programs and Swing Pricing, Form N-PORT; Outsourcing by Investment Advisers (File Nos. S7-26-22, S7-25-22; RIN 3325-AM98; RIN 3235-AN18, November 2, 2022); EU sustainable finance action plan and incorporating ESG factors into financial services; EU requirements for supply chain due diligence and disclosure; EU review of Alternative Investment Fund Managers Directive; EU review of prudential regime for investment firms; implementation and enforcement of Regulation Best Interest by the Securities and Exchange Commission; changes in the enforcement policies of the Securities and Exchange Commission; activity of the Financial Stability Oversight Council and recommendations on macro-prudential regulation; clarification in the regulatory treatment of digital assets by the Securities and Exchange Commission and the Commodity Futures Trading Commission; EU Money Market Fund Regulation, legislative review; electronic delivery of certain investment documents and disclosures; Financial Stability Board recommendations on money market fund reform; IOSCO recommendations on sustainability-related practices, polices, procedures, and disclosure in asset management; Office of Financial Research (OFR) discussions on FSOC Report on Climate-Related Financial Risk; Written responses regarding requests for comment resulting from the March 9, 2022 Executive Order on Ensuring Responsible Development of Digital Assets; FinCEN Implementation of the Beneficial Ownership Requirements of the Corporate Transparency Act (P.L. 116-283)

Client expense: $20,990,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

H.R. 1270, Prohibit Auto Insurance Discrimination (PAID) Act H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 4277, Overdraft Protection Act of 2021 H.R. 5911, Fair Hiring in Banking Act H.R. 6814, Small Business Fair Debt Collection Protection Act H.R. 7412, Transparency in CFPB Cost-Benefit Analysis Act S. 2417, Credit Access and Inclusion Act of 2021 S. 2508, Veterans and Consumers Fair Credit Act S. 3056, Prohibiting IRS Financial Surveillance Act S. 3755, Arbitration Fairness for Consumers Act Draft legislation titled Ensuring Diversity in Community Banking Act Draft legislation titled Expanding Opportunity for MDIs Act Draft legislation to provide a right of removal to federal court from CFPB administrative adjudication House companion legislation to S. 2417, Credit Access and Inclusion Act of 2021 Draft legislation subjecting the Consumer Financial Protection Bureau to the appropriations process Draft legislation to replace the Consumer Financial Protection Bureau single director with a bipartisan commission Proposed rule regarding beneficial ownership information reporting requirements (86 Fed. Reg. 69,920-69,974, December 8, 2021) Proposed rule regarding Small Business Lending Data Collection Under the Equal Credit Opportunity Act (Regulation B) (86 Fed. Reg. 56,356-56,606, October 8, 2021) Statement of Principles for Climate-Related Financial Risk Management for Large Financial Institutions (87 Fed. Reg. 19,507-19,512, April 4, 2022) Request for Information and Comment on Rules, Regulations, Guidance, and Statements of Policy Regarding Bank Merger Transactions (87 Fed. Reg. 18,740-18,744, March 31, 2022) Notice and Request for Comment Regarding Fees Imposed by Providers of Consumer Financial Products or Services (87 Fed. Reg. 17,996-17,997, March 29, 2022) Proposed rule regarding Community Reinvestment Act (87 Fed. Reg. 33,884-34,066, June 3, 2022) Advance notice of proposed rulemaking; extension of comment period, regarding credit card late fees and late payments, (87 Fed. Reg. 42,662, July 18, 2022) Various issues relating to structure and independence of the Consumer Financial Protection Bureau; artificial intelligence and machine learning; DOJ Bank Merger Competitive Analysis; OCC Request for Feedback on Principles for Climate-Related Financial Risk Management for Large Banks

Client expense: $20,990,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of

Met with House and Senate on issues impacting GSIBs Met with House and Senate on equity market structure Met with House and Senate on climate issues Met with House and Senate staff on cybersecurity issues Met with House on racial equity and diversity inclusion issues Met with House and Senate on digital assets and crypto Met with House and Senate on sanctions legislation Met with House and Senate on markets regulations Met with House on draft stablecoin legislation S.1260, United States Innovation and Competition Act of 2021 - all provisions S.2349, Protecting Consumers from Unreasonable Credit Rates Act of 2021 - all provisions S.2508, Veterans and Consumers Fair Credit Report - all provisions S.3844, Economic Continuity and Stability Act - all provisions S.4674, Credit Card Competition Act of 2022 - all provisions H.R.4521, America COMPETES Act of 2022 - issues related to outbound investments H.R.8874, The Credit Card Competition Act - all provisions

Client expense: $1,310,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Bank On Buy Now, Pay Later Central Bank Digital Currency Cryptocurrency Nominations USPS Pilot Banking Program H.R. 1996, The SAFE Banking Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2561, Promoting Access to Capital in Unbanked Communities Act of 2021 S. 910, SAFE Banking Act S.J.RES.15, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of Currency relating to "National Banks and Federal Savings Associations as Lenders." H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate LIBOR Act H.R. 5189, Member Business Loan Expansion Act S. 2508, Veterans and Consumer Fair Credit Act Perlmutter Amendment (H.Amdt.97) to H.R. 4350, National Defense Authorization Act of 2022 H.R. 2989, Financial Transparency Act H.R. 6145, Community Bank Relief Act of 2021 S. 3409, To amend the Economic Growth, Regulatory Relief, and Consumer Protection Act to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024. Emergency Capital Investment Issues for CDFI and MDI S. 3715, The E-SIGN Modernization Act Coin Circulation S. 3779, Adjustable Interest Rate LIBOR Act H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. H.R. 4277, Overdraft Protection Act of 2021 H.R 4521, America Competes Act of 2022 H.R.7003, Expanding Financial Access for Underserved Communities Act S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on Banking. H.R. 2543, Federal Reserve Racial and Economic Equity Act UDAAP Supervisory Policies and Adjudication Procedures Issues impacting the modernization of the Community Reinvestment Act Deposit Insurance Assessment Rates S.4674, Credit Card Competition Act H.R. 8874, Credit Card Competition Act H.R. 8485, Expanding Access to Credit through Consumer-Permissioned Data Act S.4760, Digital Commodities Consumer Protection Act of 2022 Merchant Category Codes

Client expense: $2,840,000 · Firm income: Not reported

Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

Proposals that would alter the vehicle sales, advertising and financing process Legislative proposals to eliminate Industrial Loan Company charters (H.R. 5912, "The Close the ILC Loophole Act") Legislative proposals to cap the interest rate on extensions of consumer credit and redefine the APR (H.R. 5974/S. 2508, "The Veterans and Consumers Fair Credit Act") Interpretation of the scope of the vehicle financing exclusion to the Military Lending Act Proposals regarding dealer participation, consumer discounts and voluntary protection products. Proposals regarding the Safeguards Rule Proposals regarding Section 1071 small business data collection Proposals related to telemarketing and advertising

Client expense: $1,533,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, SENATE

General issues related to consumer lending. H.R.5974/S.2508 - Veterans and Consumers Fair Credit Act. H.R.2543 - Federal Reserve Racial and Economic Equity Act. H.R.5912 - Close the ILC Loophole Act.

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

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

Legislative proposals impacting banking services for financial services providers; Payday, Vehicle Title, and Certain High-Cost Installment Loans; Federal policy relating to anticipated Consumer Financial Protection Bureau regulation of consumer financial services including payday and auto title lending, and regulatory process; FY2023 National Defense Authorization Act (H.R.7900, S.4543); H.R.4395, Payment Choice Act of 2021; S.2349, Protecting Consumers from Unreasonable Credit Rates Act of 2021; S.2508/H.R.5974, Veterans and Consumers Fair Credit Act; H.R.2543, Federal Reserve Racial and Economic Equity Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

General issues related to installment lending. Issues related to auto finance. S.2508 - Veterans and Consumers Fair Credit Act. H.R.6054 -Small Business Lending Disclosure Act. H.R.5912 - Close the ILC Loophole Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE, White House Office

Issues related to banking regulatory reform: -HR 1277/S 374 Improving Corporate Governance Through Diversity Act of 2021 -HR 4258 To establish a governmentwide approach to improving digital identity, and for other purposes. -Issues related to interest rate caps -HR 745 Fair Access to Credit Act of 2021 -HR 7900 National Defense Authorization Act for Fiscal Year 2023 (issues related to banking) -HR 4373 Further Additional Continuing Appropriations and Extensions Act, 2023 -Issues related to credit scores -HR 1491 Fair Debt Collection Practices for Servicemembers Act -HR 1645 To amend the Fair Credit Reporting Act to make improvements to the regulation of consumer reporting agencies and protect consumers, and for other purposes. -HR 166 Fair Lending for All Act -HR 5376 Build Back Better Act -HR 5974/S 2508 Veterans and Consumers Fair Credit Act -Issues related to unfair, deceptive, and abusive acts and practices -Issues related to financial innovation -Issues related to financial literacy -Issues related to the Community Reinvestment Act -Issues related to debt collection -Issues related to artificial intelligence and machine learning -Issues related to credit scoring/credit risk -Issues related to privacy -HR 8152 American Data Privacy and Protection Act -S 4356 Lummis-Gillibrand Responsible Financial Innovation Act -S. 4674 Credit Card Competition Act -Issues related to diversity, equity, and inclusion -Issues related to anti-trust -Issues related to fees -Issues related to climate -Issues related to digital assets

Client expense: $380,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), SENATE, Treasury, Dept of

Issues related to the regulation of insurance products and voluntary protection products. Issues related to S. 2508/H.R. 5974, The Veterans and Consumers Fair Credit Act.

Client expense: Not reported · Firm income: $40,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

General issues related to installment lending. Issues related to auto finance. S.2508 - Veterans and Consumers Fair Credit Act. H.R.6054 -Small Business Lending Disclosure Act. H.R.5912 - Close the ILC Loophole Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE, White House Office

General issues related to consumer lending. H.R.5974/S.2508 - Veterans and Consumers Fair Credit Act. H.R.4395 - Payment Choice Act of 2021. H.R.2543 - Federal Reserve Racial and Economic Equity Act. H.R.5912 - Close the ILC Loophole Act.

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

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

Met with House and Senate on issues impacting GSIBs Met with House and Senate on Fintech charters and issues Met with House and Senate on equity market structure Met with House and Senate on climate issues Met with House and Senate staff on cybersecurity issues Met with House on racial equity and diversity inclusion issues Met with House and Senate on digital assets and crypto Met with House and Senate on sanctions legislation Met with House and Senate on markets regulations Met with House on draft stablecoin legislation S.1260, United States Innovation and Competition Act of 2021 - all provisions S.2349, Protecting Consumers from Unreasonable Credit Rates Act of 2021 - all provisions S.2508, Veterans and Consumers Fair Credit Report - all provisions S.3755, Arbitration Fairness for Consumers Act - all provisions S.3844, Economic Continuity and Stability Act - all provisions S.4674, Credit Card Competition Act of 2022 - all provisions H.R.963, Forced Arbitration Injustice Repeal Act - all provisions H.R.4521, America COMPETES Act of 2022 - issues related to outbound investments H.R.8874, The Credit Card Competition Act - all provisions

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 1270, Prohibit Auto Insurance Discrimination (PAID) Act H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 4277, Overdraft Protection Act of 2021 H.R. 5911, Fair Hiring in Banking Act H.R. 6814, Small Business Fair Debt Collection Protection Act H.R. 7412, Transparency in CFPB Cost-Benefit Analysis Act S. 2417, Credit Access and Inclusion Act of 2021 S. 2508, Veterans and Consumers Fair Credit Act S. 3056, Prohibiting IRS Financial Surveillance Act S. 3755, Arbitration Fairness for Consumers Act Draft legislation titled Ensuring Diversity in Community Banking Act Draft legislation titled Expanding Opportunity for MDIs Act Draft legislation to create a government-run credit bureau at the Consumer Financial Protection Bureau Draft legislation to provide a right of removal to federal court from administrative adjudication House companion legislation to S. 2417, Credit Access and Inclusion Act of 2021 Proposed rule regarding reinstatement of HUDs Discriminatory Effects Standard (86 Fed. Reg. 33,590-33,597, June 25, 2021) Proposed rule regarding beneficial ownership information reporting requirements (86 Fed. Reg. 69,920-69,974, December 8, 2021) Proposed interagency guidance on third-party relationships: risk management (86 Fed. Reg. 38,182-38,204, July 19, 2021) Review of Bank Secrecy Act regulations and guidance (86 Fed. Reg. 71,201-71,207, December 15, 2021) Proposed rule regarding Small Business Lending Data Collection Under the Equal Credit Opportunity Act (Regulation B) (86 Fed. Reg. 56,356-56,606, October 8, 2021) Statement of Principles for Climate-Related Financial Risk Management for Large Financial Institutions (87 Fed. Reg. 19,507-19,512, April 4, 2022) Request for Information and Comment on Rules, Regulations, Guidance, and Statements of Policy Regarding Bank Merger Transactions (87 Fed. Reg. 18,740-18,744, March 31, 2022) Notice and Request for Comment Regarding Fees Imposed by Providers of Consumer Financial Products or Services (87 Fed. Reg. 17,996-17,997, March 29, 2022) Proposed rule regarding Community Reinvestment Act (87 Fed. Reg. 33,884-34,066, June 3, 2022) Advance notice of proposed rulemaking; extension of comment period, regarding credit card late fees and late payments, (87 Fed. Reg. 42,662, July 18, 2022) Various issues relating to structure and independence of the Consumer Financial Protection Bureau; artificial intelligence and machine learning; congressional oversight of large banks; Department of Treasury proposal that would require financial institutions to report to the IRS on the deposits and withdrawals of all business and personal accounts, as well as transfers between accounts of the same owner; DOJ Bank Merger Competitive Analysis; OCC Request for Feedback on Principles for Climate-Related Financial Risk Management for Large Banks

Client expense: $23,940,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Justice, Dept of (DOJ), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of

H.R. 935, Small Business Mergers, Acquisitions, Sales, and Brokerage Simplification Act of 2021 H.R. 1087, Shareholder Political Transparency Act of 2021 H.R. 1187, Corporate Governance Improvement and Investor Protection Act H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 1602, Eliminate Barriers to Innovation Act of 2021 H.R. 2025/S. 840, To amend title 28, United States Code, to increase transparency and oversight of third-party litigation funding in certain actions, and for other purposes H.R. 2516, Promoting Diversity and Inclusion in Banking Act of 2021 H.R. 2543, Federal Reserve Racial and Economic Equity Act H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2570, Climate Risk Disclosure Act of 2021 H.R. 2620, Investor Choice Act of 2021 H.R. 3007, Disclosure of Tax Havens and Offshoring Act H.R. 3448, Helping Startups Continue to Grow Act H.R. 3454, Modernizing Disclosures for Investors Act H.R. 3843, Merger Filing Fee Modernization Act of 2022 H.R. 4277, Overdraft Protection Act of 2021 H.R. 4345, Financial Services and General Government Appropriations Act, 2022 H.R. 4521, America Creating Opportunities for Manufacturing, Pre-Eminence in Technology, and Economic Strength (America COMPETES) Act of 2022, including provisions related to House Amendment 218 H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate (LIBOR) Act of 2021 H.R. 4773, Consumer Financial Protection Commission Act H.R. 5586/S. 3056, Prohibiting IRS Financial Surveillance Act H.R. 5648/S. 3022, Stop Wall Street Looting Act H.R. 5910, Holding SPACs Accountable Act of 2021 H.R. 5911, Fair Hiring in Banking Act H.R. 7151, Ensuring Sound Guidance Act H.R. 7900, National Defense Authorization Act for Fiscal Year 2023 H.R. 7977, Promoting Opportunities for Non-Traditional Capital Formation Act H.R. 8254/S. 4685, Financial Services and General Government Appropriations Act, 2023 H.R. 8521, Investor Democracy is Expected (INDEX) Act S. 479, Lifting Our Communities through Advance Liquidity for (LOCAL) Infrastructure Act S. 2417, Credit Access and Inclusion Act of 2021 S. 2508, Veterans and Consumers Fair Credit Act S. 2621, Modernization of Derivatives Tax Act of 2021 S. 3410, The Consumer Protection and Due Process Act S. 3755, Arbitration Fairness for Consumers Act S. 3844, Economic Continuity and Stability Act S. 3914, Developing and Empowering our Aspiring Leaders Act of 2022 S. 4241, Investor Democracy is Expected (INDEX) Act Draft legislation titled Jumpstart our Business Startups (JOBS) Act 4.0 of 2022 Draft legislation titled Mandatory Materiality Requirement Act of 2022 Potential legislation to foster economic growth and job creation through capital formation Potential legislation to further economic growth through environmental, social, and governance factors Potential legislation to make changes to the Exchange Act Rule 14a-8 shareholder proposal process Potential legislation to hold proxy voting advice businesses accountable Potential legislation to expressing a sense of Congress reaffirming the Supreme Court materiality standard Potential legislation to require the SEC to consider additional standards in the rulemaking process Potential legislation to study the term small entity Potential legislation regarding a new regulatory framework for stablecoins Potential legislation dealing with third party litigation financing and lawsuit lending Potential legislation dealing with securities litigation Nomination of Mark Uyeda to be Commissioner of the U.S. Securities and Exchange Commission (SEC) Proposed rule regarding SEC Enhanced Reporting of Proxy Votes by Registered Management Investment Companies; Reporting of Executive Compensation Votes by Institutional Investment Managers Proposed Rule (86 Fed. Reg. 57,478-57,524, October 15, 2021) Proposed rule regarding Position Reporting of Large Security-Based Swap Positions (87 Fed. Reg. 6,652-6,706, December 15, 2021) SEC Money Market Fund Reforms (86 Fed. Reg. 7,248, December 15, 2021) Proposed rules regarding amendments to Form PF (87 Fed. Reg. 9,106-9,235, January 26, 2022) Proposed rule regarding Share Repurchase Disclosure Modernization (87 Fed. Reg. 8,443-8,472, February 15, 2022) Proposed Rule, Securities and Exchange Commission; Prohibition Against Fraud, Manipulation, or Deception in Connection with Security-Based Swaps, Prohibition against Undue Influence over Chief Compliance Officers, Position Reporting of Large Security-Based Swap Positions (87 Fed. Reg. 6,652-6,706, February 4, 2022) Proposed rule on Enhancement and Standardization of Climate-Related Disclosures for Investors (87 Fed. Reg. 21,334-21,473, April 11,2022) Proposed Rule, Securities and Exchange Commission; Enhanced Disclosures by Certain Investment Advisers and Investment Companies About Environmental, Social, and Governance Investment Practices (87 Fed. Reg. 36,654-36,761, June 17, 2022) Proposed Rule, Securities and Exchange Commission; Investment Company Names (87 Fed. Reg. 36,594-36,651, June 17,2022) Proposed Rule, Securities and Exchange Commission; Share Repurchase Disclosure Modernization (87 Fed. Reg. 8,443-8,472, April 1, 2022) Proposed Rule, Securities and Exchange Commission; Substantial Implementation, Duplication, and Resubmission of Shareholder Proposals Under Exchange Act Rule 14a-8 (87 Fed. Reg. 45,052-45,075. July 27, 2022) Request for Comment on Certain Information Providers Acting as Investment Advisers; Securities and Exchange Commission (87 Fed. Reg. 37,254-37,262, June 22, 2022) Request for Comment, Bureau of Consumer Financial Protection; Agency Information Collection Activities, Report of Terms of Credit Card Plans (Form FR 2572) and Consumer and College Credit Card Agreements (87 Fed. Reg. 50,851-50,852, August 18, 2022) Advance Notice of Proposed Rulemaking, Bureau of Consumer Financial Protection; Credit Card Late Fees and Late Payments (87 Fed. Reg. 42,662, July 18, 2022) Joint Notice of Proposed Rulemaking, Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation, Federal Reserve System; Community Reinvestment Act (87 Fed. Reg. 33,884-34,066, June 3, 2022) Request for Comments, Department of the Treasury; Ensuring Responsible Development of Digital Assets (87 Fed. Reg. 40,881-40,883, July 8, 2022) Request for Comment, International Trade Administration; Developing a Framework on Competitiveness of Digital Asset Technologies (87 Fed. Reg. 30450- 30452, May 19, 2022) Various issues relating to SEC Best Interest and Enhancing Investment Adviser Regulation relating to broker-dealers, registered investment advisers, conflicts of interest; potential federal preemption of state fiduciary standards; Public Company Accounting Oversight Board (PCAOB); CFTCs de minimis Exception for Swap Dealers; Securities and Exchange Commission amendments to the Commissioners whistleblower rules file no. S7-16-18; proxy process, proxy advisory firms, and other related aspects of corporate governance; corporate common ownership; adoption of the current expected credit loss (CECL) accounting standard; role of credit reporting agencies (CRAs) in the U.S. economy; debt collection practices (regulation F) under the Fair Debt Collection Practices Act (P.L. 95-109); qualified mortgage definition under the Truth in Lending Act (P.L. 90-321) (Regulation Z); Financial Stability Oversight Council and the designation of Nonbank Financial Firms as systemically important; Federal Reserve Systems Large Institution Supervision Coordinating Committee; potential housing finance reform legislation; enforcement of Securities and Exchange Commission penalties; potential repeal of the State and Local Tax (SALT) Cap; federal interest rate authority; Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) reform; electronic consent-based SSN Verification Service (eCBSV); environmental, social, and governance (ESG) enforcement; information Collection under the Community Reinvestment Act (CRA); potential Financial Transaction Tax (FTT); potential Treasury Department proposal relating to tax reporting by banks; investment company cross trading; potential money market fund reform measures; resolutions to establish task forces on Artificial Intelligence and Financial Technology in the House Committee on Financial Services; transition to the secured overnight financing rate; implementation of SEC Rule 15c2-11; Department of Labor fiduciary advice exemption: PTE 2020-02; benefits of risk-based pricing; mobile disclosures; Federal Trade Commission issues: Freedom of Information Act Requests, Penalty Offense Authority, Zombie Voting, and overall direction of the Commission under Chair Lina Khan; Tax Reporting Proposal by the Department of the Treasury related to a $600 or more annual account threshold; Amendment to the FY22 National Defense Authorization Act related to credit reporting; Climate-Related Financial Risk Management for Large Banks; House Committee on Financial Services request for information related to Russia sanctions; CFPB Policy Fellowship program; CFPB amendment of its Supervision and Examination Manual; CFPB conflation of Distinct Statutory Concepts of Unfairness and Discrimination; Promoting the importance of appropriate length of SEC Comment Periods; Internal Revenue Service; Priority Guidance Plan; Compliance Assistance Release, Department of Labor; 401(k) Plan Investments in Cryptocurrencies Request for Information, Consumer Financial Protection Bureau; Fees Imposed by Providers of Consumer Financial Products or Services; Notice of Inquiry, Federal Communications Commission; In the Matter of Implementing the Infrastructure Investment and Jobs Act: Prevention and Elimination of Digital Discrimination; (GN Docket No. 22-69); EU sustainable finance action plan and incorporating ESG factors into financial services; EU review of Alternative Investment Fund Managers Directive; EU review of prudential regime for investment firms; implementation and enforcement of Regulation Best Interest by the Securities and Exchange Commission; changes in the enforcement policies of the Securities and Exchange Commission; activity of the Financial Stability Oversight Council and recommendations on macro-prudential regulation; clarification in the regulatory treatment of digital assets by the Securities and Exchange Commission and the Commodity Futures Trading Commission; implementation and enforcement of proxy advisory firm regulations finalized in 2020; implementation and enforcement of SEC 14a-8 shareholder proposal process reforms finalized in 2020; EU Money Market Fund Regulation, legislative review; electronic delivery of certain investment documents and disclosures; implementation of beneficial ownership reporting requirements under the National Defense Authorization Act FY2021 (P.L. 116-283); implementation of the Social Security Administrations Electronic Consent Based Social Security Number Verification System Service; Financial Stability Board recommendations on money market fund reform; IOSCO recommendations on sustainability-related practices, polices, procedures, and disclosure in asset management; Office of Financial Research (OFR) discussions on FSOC Report on Climate-Related Financial Risk; staff legal guidance at the SEC concerning no-action letters on shareholder proposals with broad societal impact (Staff Legal Bulletin 14L-CF); SEC Reforms to regulations related to Cybersecurity Disclosures; SEC Reforms to regulations related to Human Capital Management Disclosures; SEC Reforms to regulations related to proxy voting advice businesses; SEC request for information on digital engagement practices; Written responses regarding requests for comment resulting from the March 9, 2022 Executive Order on Ensuring Responsible Development of Digital Assets; SEC Proposed Rule amending 10b5-1; SEC Proposed Rule on Private Fund Advisers; Documentation of Registered Investment Adviser Compliance Reviews; SEC Amended Rule 15c2-11, applicability to 144A securities; SEC Proposed Rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors; SEC Substantial Implementation, Duplication, and Resubmission of Shareholder Proposals Under Exchange Act Rule 14a-8; PCAOB 2022-2026 Draft Strategic Plan; SEC FY 22-26 Strategic Plan; FinCEN Implementation of the Beneficial Ownership Requirements of the Corporate Transparency Act (P.L. 116-283)

Client expense: $23,940,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

While MCUL takes no position on the issue of cannabis legalization, it supports legislation in the 117th Congress that would provide a safe harbor for financial institutions to serve their members needs in states where cannabis use has become legal. MCUL supports the SAFE Banking Act of 2021, S. 910 and H.R. 1996 which would provide a safe harbor for credit unions and other financial institutions. MCUL stands opposed to efforts to change the existing interchange system by expanding requirements under the so-called Durbin Amendment established under the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. We have been educating our delegation on the importance of the current credit card interchange system with regard to ensuring consumer data remains secure and private and are asking our delegation to oppose S. 4674/H.R. 8874, the Credit Card Competition Act of 2022 because of the harm it would do to credit unions, their members, along with other financial institutions and their customers. We continue to educate our congressional delegation on voluntary overdraft protection services offered by credit unions and the value our members place on these services. MCUL is opposed to legislation (H.R. 4277 and S. 2677) that would severely limit a financial institutions ability to offer these voluntary services to our members. MCUL supports and is calling for passage of H.R. 3962 and S.1625, the SECURE Notarization Act that would establish minimum standards for electronic and remote notarization. We are also educating our delegation on the importance of updating the 20 year old E-sign Act to better reflect how customers can signal their acceptance of electronic transactions. MCUL is opposed to S. 2508, the Veteran's and Consumer Fair Credit Act that would extend provisions of the Military Lending Act (MLA), which establishes a 36% all-in rate cap on most loans to service members, to all consumer loans. The all-in cap would make it very difficult for credit unions to maintain viable small-dollar programs and severely hinder a state credit union's ability to offer overdraft products.

Client expense: $10,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Legislative proposals impacting banking services for financial services providers; Payday, Vehicle Title, and Certain High-Cost Installment Loans; Federal policy relating to anticipated Consumer Financial Protection Bureau regulation of consumer financial services including payday and auto title lending, and regulatory process; FY2023 National Defense Authorization Act (H.R.7900, S.4543); H.R.4395, Payment Choice Act of 2021; S.2349, Protecting Consumers from Unreasonable Credit Rates Act of 2021; S.2508/H.R.5974, Veterans and Consumers Fair Credit Act; H.R.2543, Federal Reserve Racial and Economic Equity Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Proposals that would alter the vehicle sales, advertising and financing process Legislative proposals to eliminate Industrial Loan Company charters (H.R. 5912, "The Close the ILC Loophole Act") Legislative proposals to cap the interest rate on extensions of consumer credit and redefine the APR (H.R. 5974/S. 2508, "The Veterans and Consumers Fair Credit Act") Proposals regarding dealer participation, consumer discounts and voluntary protection products. Proposals regarding the Safeguards Rule Proposals regarding Section 1071 small business data collection Proposals related to telemarketing and advertising Interpretation of the scope of the vehicle financing exclusion to the Military Lending Act

Client expense: $1,736,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, SENATE

All legislation related to consumer lending regulation and consumer lending policy. S. 2349, the Protecting Consumers from Unreasonable Credit Rates Act of 2021. S. 2508, the Veterans and Consumers Fair Credit Act of 2021. H.R. 5974, Veterans and Consumers Fair Credit Act.

Client expense: Not reported · Firm income: $70,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Bank On Buy Now, Pay Later Central Bank Digital Currency Cryptocurrency Nominations USPS Pilot Banking Program H.R. 1996, The SAFE Banking Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2561, Promoting Access to Capital in Unbanked Communities Act of 2021 S. 910, SAFE Banking Act S.J.RES.15, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of Currency relating to "National Banks and Federal Savings Associations as Lenders." H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate LIBOR Act H.R. 5189, Member Business Loan Expansion Act S. 2508, Veterans and Consumer Fair Credit Act Perlmutter Amendment (H.Amdt.97) to H.R. 4350, National Defense Authorization Act of 2022 H.R. 2989, Financial Transparency Act H.R. 6145, Community Bank Relief Act of 2021 S. 3409, To amend the Economic Growth, Regulatory Relief, and Consumer Protection Act to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024. Emergency Capital Investment Issues for CDFI and MDI S. 3715, The E-SIGN Modernization Act Coin Circulation S. 3779, Adjustable Interest Rate LIBOR Act H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. H.R. 4277, Overdraft Protection Act of 2021 H.R 4521, America Competes Act of 2022 H.R.7003, Expanding Financial Access for Underserved Communities Act S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on Banking. H.R. 2543, Federal Reserve Racial and Economic Equity Act UDAAP Supervisory Policies and Adjudication Procedures Issues impacting the modernization of the Community Reinvestment Act Deposit Insurance Assessment Rates S.4674, Credit Card Competition Act H.R. 8874, Credit Card Competition Act H.R. 8485, Expanding Access to Credit through Consumer-Permissioned Data Act S.4760, Digital Commodities Consumer Protection Act of 2022 Merchant Category Codes

Client expense: $2,870,000 · Firm income: Not reported

Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

Issues related to banking regulatory reform: -HR 1277/S 374 Improving Corporate Governance Through Diversity Act of 2021 -HR 4258 To establish a governmentwide approach to improving digital identity, and for other purposes. -Issues related to interest rate caps -HR 745 Fair Access to Credit Act of 2021 -HR 4350 National Defense Authorization Act for Fiscal Year 2022 (issues related to banking) -Issues related to credit scores -HR 1491 Fair Debt Collection Practices for Servicemembers Act -HR 1645 To amend the Fair Credit Reporting Act to make improvements to the regulation of consumer reporting agencies and protect consumers, and for other purposes. -HR 166 Fair Lending for All Act -HR 5376 Build Back Better Act -HR 5974/S 2508 Veterans and Consumers Fair Credit Act -Issues related to unfair, deceptive, and abusive acts and practices -Issues related to financial innovation -Issues related to financial literacy -Issues related to the Community Reinvestment Act -Issues related to debt collection -Issues related to artificial intelligence and machine learning -Issues related to credit scoring/credit risk -Issues related to privacy -HR 8152 American Data Privacy and Protection Act -S 4356 Lummis-Gillibrand Responsible Financial Innovation Act -S. 4674 Credit Card Competition Act -Issues related to diversity, equity, and inclusion -Issues related to anti-trust -Issues related to fees -Issues related to climate -Issues related to digital assets

Client expense: $430,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), SENATE, Treasury, Dept of

Issues related to the regulation of insurance products and voluntary protection products. Issues related to S. 2508/H.R. 5974, The Veterans and Consumers Fair Credit Act.

Client expense: Not reported · Firm income: $40,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Federal policy relating to anticipated Consumer Financial Protection Bureau regulation of consumer financial services including payday lending, auto title lending, and regulatory process. Potential legislation to regulate interest rates on financial products. S.J. Res. 15 - A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders." Implementation of the CARES Act (PL 116-136), provisions relating to the payroll protection program. Implementation of the American Rescue Plan Act of 2021 (PL-117-2), provisions relating to the payroll protection program. Legislative proposals relating to prohibiting retail businesses from refusing cash payments. H.R. 2040, The Financial Reporting Threshold Modernization Act, provisions relating to updating thresholds for certain currency transaction reports and suspicious activity reports. H.R. 1996, The SAFE Banking Act of 2021, provisions relating to the provision of financial services to cannabis-related businesses and service providers S. 563, The Fair Access to Banking Act, provisions relating to fair access to financial services and discount window lending programs. Veterans and Consumers Fair Credit Act (H.R. 5974/S. 2508), provisions relating to regulation of interest rates on financial products.

Client expense: Not reported · Firm income: $50,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S2508 and HR 5974 VCFCA Proprietary Education Oversight Coordination Improvement Act

Client expense: $100,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

All legislation related to consumer lending regulation and consumer lending policy. S. 2349, the Protecting Consumers from Unreasonable Credit Rates Act of 2021. S. 2508, the Veterans and Consumers Fair Credit Act of 2021. H.R. 5974, Veterans and Consumers Fair Credit Act.

Client expense: Not reported · Firm income: $70,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Closing the "rent-a-bank" loophole to bypass state regulations on usury caps Increased supervision and enforcement of BNPL and EWA Eliminating excessive banking fees, including overdraft Lender robosigning on collections for consumer credit CFPB rules of practice for adjudication proceedings Review merger of TD Bank Principles for responsible consumer and small business loans to prevent predatory lending Review and regulation of "junk fees" CFPB Examination of Nonbank mortgage, private loan, and payday loan entities Applicability of CFPB 1071 Rule to Farm Credit System Mandatory arbitration by credit monitoring agencies on reportable FCRA/FCBA complaints Urge CFPB reexamination of current late fee safe harbor amounts on credit cards H.R.5912 - Close the ILC Loophole Act, a bill to reform the regulation of industrial loan companies and their parent companies H.R.5974 / S.2508 - Veterans and Consumers Fair Credit Act, a bill to amend the Truth in Lending Act to extend the consumer credit protections provided to members of the Armed Forces and their dependents under title 10, United States Code, to all consumers S. 2677 - Stop Overdraft Profiteering Act, a bill to prohibit depository institutions from engaging in certain acts in connection with overdraft coverage S. 345 / H.R. 4277 - Overdraft Protection Act, a bill to prohibit a financial institution from engaging in unfair or deceptive acts in connection with overdraft coverage H.R. 2543 - FFederal Reserve Racial and Economic Equity Act, a bill to address access to financial services, diversity in various financial institutions and establishments, and other related issues H.R.6889 - Credit Union Board Modernization Act, a bill to amend the Federal Credit Union Act to modify the frequency of board of directors meetings, and for other purposes Nomination of Michael Barr to the Federal Reserve Board of Governors Namination of Lael Brainard to Federal Reserve Board of Governors Nomination of Lisa Cook to the Federal Reserve Board of Governors Nomination of Todd Harper to the National Credit Union Administration

Client expense: $80,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of

Proposals affecting automotive finance Legislative proposals to eliminate Industrial Loan Company charters (H.R. 5912, "The Close the ILC Loophole Act") Legislative proposals to cap the interest rate on extensions of consumer credit and redefine the APR (H.R. 5974/S. 2508, "The Veterans and Consumers Fair Credit Act") Proposals regarding dealer participation, consumer discounts and voluntary protection products. Proposals regarding the Safeguards Rule Proposals regarding Section 1071 small business data collection Proposals related to telemarketing and advertising

Client expense: $1,215,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, SENATE

General issues related to consumer lending. H.R. 5974/S. 2508, the Veterans and Consumers Fair Credit Act. H.R. 4395, the Payment Choice Act. H.R. 2543, Federal Reserve Racial and Economic Equality Act. H.R. 5912 - Close the ILC Loophole Act.

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

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

Bank On Buy Now, Pay Later Central Bank Digital Currency Cryptocurrency Durbin Interchange Nominations USPS Pilot Banking Program H.R. 1996, The SAFE Banking Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2561, Promoting Access to Capital in Unbanked Communities Act of 2021 S. 910, SAFE Banking Act S.J.RES.15, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of Currency relating to "National Banks and Federal Savings Associations as Lenders." H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate LIBOR Act H.R. 5189, Member Business Loan Expansion Act S. 2508, Veterans and Consumer Fair Credit Act Perlmutter Amendment (H.Amdt.97) to H.R. 4350, National Defense Authorization Act of 2022 H.R. 2989, Financial Transparency Act H.R. 6145, Community Bank Relief Act of 2021 S. 3409, To amend the Economic Growth, Regulatory Relief, and Consumer Protection Act to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024. Emergency Capital Investment Issues for CDFI and MDI S. 3715, The E-SIGN Modernization Act Coin Circulation S. 3779, Adjustable Interest Rate LIBOR Act H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. H.R. 4277, Overdraft Protection Act of 2021 H.R 4521, America Competes Act of 2022 H.R.7003, Expanding Financial Access for Underserved Communities Act S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on Banking. H.R. 2543, Federal Reserve Racial and Economic Equity Act UDAAP Supervisory Policies and Adjudication Procedures Bank On Buy Now, Pay Later Central Bank Digital Currency Cryptocurrency Durbin Interchange Nominations USPS Pilot Banking Program H.R. 1996, The SAFE Banking Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2561, Promoting Access to Capital in Unbanked Communities Act of 2021 S. 910, SAFE Banking Act S.J.RES.15, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of Currency relating to "National Banks and Federal Savings Associations as Lenders." H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate LIBOR Act H.R. 5189, Member Business Loan Expansion Act S. 2508, Veterans and Consumer Fair Credit Act Perlmutter Amendment (H.Amdt.97) to H.R. 4350, National Defense Authorization Act of 2022 H.R. 2989, Financial Transparency Act H.R. 6145, Community Bank Relief Act of 2021 S. 3409, To amend the Economic Growth, Regulatory Relief, and Consumer Protection Act to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024. Emergency Capital Investment Issues for CDFI and MDI S. 3715, The E-SIGN Modernization Act Coin Circulation S. 3779, Adjustable Interest Rate LIBOR Act H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. H.R. 4277, Overdraft Protection Act of 2021 H.R 4521, America Competes Act of 2022 H.R.7003, Expanding Financial Access for Underserved Communities Act S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on Banking. H.R. 2543, Federal Reserve Racial and Economic Equity Act UDAAP Supervisory Policies and Adjudication Procedures

Client expense: $1,740,000 · Firm income: Not reported

Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

General issues related to installment lending. Issues related to auto finance. S. 2508, the Veterans and Consumers Fair Credit Act; H.R. 6054, the Small Business Lending Disclosure Act; H.R. 5912, the Close the ILC Loophole Act

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE, White House Office

Bank On Buy Now, Pay Later Central Bank Digital Currency Cryptocurrency Durbin Interchange Nominations USPS Pilot Banking Program H.R. 1996, The SAFE Banking Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2561, Promoting Access to Capital in Unbanked Communities Act of 2021 S. 910, SAFE Banking Act S.J.RES.15, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of Currency relating to "National Banks and Federal Savings Associations as Lenders." H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate LIBOR Act H.R. 5189, Member Business Loan Expansion Act S. 2508, Veterans and Consumer Fair Credit Act Perlmutter Amendment (H.Amdt.97) to H.R. 4350, National Defense Authorization Act of 2022 H.R. 2989, Financial Transparency Act H.R. 6145, Community Bank Relief Act of 2021 S. 3409, To amend the Economic Growth, Regulatory Relief, and Consumer Protection Act to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024. Emergency Capital Investment Issues for CDFI and MDI S. 3715, The E-SIGN Modernization Act Coin Circulation S. 3779, Adjustable Interest Rate LIBOR Act H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. H.R. 4277, Overdraft Protection Act of 2021 H.R 4521, America Competes Act of 2022 H.R.7003, Expanding Financial Access for Underserved Communities Act

Client expense: $1,666,000 · Firm income: Not reported

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

Met with House and Senate on issues impacting GSIBs Met with House and Senate on Fintech charters and issues Met with House and Senate on industrial loan corporations Met with House and Senate on equity market structure Met with House and Senate on climate issues Met with House and Senate staff on cybersecurity issues Met with House on racial equity and diversity inclusion issues Met with House and Senate on digital assets and crypto Met with House and Senate on sanctions legislation Met with House and Senate on markets regulations S.1260, United States Innovation and Competition Act of 2021 - all provisions S.2349, Protecting Consumers from Unreasonable Credit Rates Act of 2021 - all provisions S.2508, Veterans and Consumers Fair Credit Report - all provisions S.3755, Arbitration Fairness for Consumers Act - all provisions S.3844, Economic Continuity and Stability Act - all provisions H.R.963, Forced Arbitration Injustice Repeal Act - all provisions H.R.4521, America COMPETES Act of 2022 - issues related to outbound investments

Client expense: $1,160,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 935, Small Business Mergers, Acquisitions, Sales, and Brokerage Simplification Act of 2021 H.R. 1087, Shareholder Political Transparency Act of 2021 H.R. 1187, Corporate Governance Improvement and Investor Protection Act H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 1602, Eliminate Barriers to Innovation Act of 2021 H.R. 2025/S. 840, To amend title 28, United States Code, to increase transparency and oversight of third-party litigation funding in certain actions, and for other purposes H.R. 2516, Promoting Diversity and Inclusion in Banking Act of 2021 H.R. 2543, Federal Reserve Racial and Economic Equity Act H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2570, Climate Risk Disclosure Act of 2021 H.R. 2620, Investor Choice Act of 2021 H.R. 3007, Disclosure of Tax Havens and Offshoring Act H.R. 3448, Helping Startups Continue to Grow Act H.R. 3454, Modernizing Disclosures for Investors Act H.R. 4277, Overdraft Protection Act of 2021 H.R. 4345, Financial Services and General Government Appropriations Act, 2022 H.R. 4350, National Defense Authorization Act for Fiscal Year 2022 H.R. 4521, America Creating Opportunities for Manufacturing, Pre-Eminence in Technology, and Economic Strength (America COMPETES) Act of 2022, including provisions related to House Amendment 218 H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate (LIBOR) Act of 2021 H.R. 4773, Consumer Financial Protection Commission Act H.R. 5586/S. 3056, Prohibiting IRS Financial Surveillance Act H.R. 5648/S. 3022, Stop Wall Street Looting Act H.R. 5910, Holding SPACs Accountable Act of 2021 H.R. 5911, Fair Hiring in Banking Act H.R. 7977, Promoting Opportunities for Non-Traditional Capital Formation Act S. 479, Lifting Our Communities through Advance Liquidity for (LOCAL) Infrastructure Act S. 2417, Credit Access and Inclusion Act of 2021 S. 2508, Veterans and Consumers Fair Credit Act S. 2621, Modernization of Derivatives Tax Act of 2021 S. 3410, The Consumer Protection and Due Process Act S. 3844, Economic Continuity and Stability Act S. 3914, Developing and Empowering our Aspiring Leaders Act of 2022 S. 4241, INvestor Democracy is EXpected (INDEX) Act Draft legislation titled Jumpstart our Business Startups (JOBS) Act 4.0 of 2022 Draft legislation titled Making appropriations for Financial Services and General Government for the fiscal year ending September 30, 2023, and for other purposes Potential legislation to foster economic growth and job creation through capital formation Potential legislation to further economic growth through environmental, social, and governance factors Potential legislation to speed up the timeline of the Holding Foreign Companies Accountable Act Potential legislation to enshrine SEC threshold ownership requirements for shareholder proposals Potential legislation to require the SEC to study barriers in accessing capital for minority entrepreneurs Potential legislation to expressing a sense of Congress reaffirming the Supreme Court materiality standard Potential legislation to require the SEC to consider additional standards in the rulemaking process Nomination of Mark Uyeda to be Commissioner of the U.S. Securities and Exchange Commission (SEC) Proposed rule regarding SEC Enhanced Reporting of Proxy Votes by Registered Management Investment Companies; Reporting of Executive Compensation Votes by Institutional Investment Managers Proposed Rule (86 Fed. Reg. 57,478-57,524, October 15, 2021) Proposed rule regarding SEC Reporting of Securities Loans (86 Fed. Reg. 69,802-69,853, December 8, 2021) Proposed rule regarding Position Reporting of Large Security-Based Swap Positions (87 Fed. Reg. 6,652-6,706, December 15, 2021) SEC Money Market Fund Reforms (86 Fed. Reg. 7,248, December 15, 2021) Proposed rules regarding amendments to Form PF (87 Fed. Reg. 9,106-9,235, January 26, 2022) Request for Information Regarding Fees Imposed by Providers of Consumer Financial Products or Services, Consumer Financial Protection Bureau; (87 Fed. Reg. 5,801-5,803, February 2, 2022) Request for Comment, Board of Governors of the Federal Reserve System; Framework for the Supervision of Insurance Organizations (87 Fed. Reg. 6,537-6,549, February 4, 2022) Procedural Rule, Request for Comment, Consumer Financial Protection Bureau; Supervisory Authority Over Certain Nonbank Covered Persons Based on Risk Determination; Public Release of Decisions and Orders (87 Fed. Reg. 25397-25398, April 29, 2022) Proposed Rule, Consumer Financial Protection Bureau; Prohibition on Inclusion of Adverse Information in Consumer Reporting in Cases of Human Trafficking (Regulation V) (87 Fed. Reg. 20,771-20,781, April 8, 2022) Proposed Rule, Federal Deposit Insurance Corporation; Rules, Regulations, Guidance, and Statement of Policy on Bank Merger Transactions (87 Fed. Reg. 18,740-18,744, March 31, 2022) Proposed Rule; Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure (87 Fed. Reg. 16,590-16,624, May 9, 2022) Proposed Rule, Securities and Exchange Commission; Private Fund Advisers; Documentation of Registered Investment Adviser Compliance Reviews (87 Fed. Reg. 16,886-16,977, March 24, 2022) Request for Comment, Federal Deposit Insurance Corporation; Statement of Principles for Climate-Related Financial Risk Management for Large Financial Institutions (87 Fed. Reg. 19,507-19,512, April 4, 2022) Various issues relating to SEC Best Interest and Enhancing Investment Adviser Regulation relating to broker-dealers, registered investment advisers, conflicts of interest; potential federal preemption of state fiduciary standards; Public Company Accounting Oversight Board (PCAOB); CFTCs de minimis Exception for Swap Dealers; Securities and Exchange Commission amendments to the Commissioners whistleblower rules file no. S7-16-18; proxy process, proxy advisory firms, and other related aspects of corporate governance; corporate common ownership; adoption of the current expected credit loss (CECL) accounting standard; role of credit reporting agencies (CRAs) in the U.S. economy; debt collection practices (regulation F) under the Fair Debt Collection Practices Act (P.L. 95-109); qualified mortgage definition under the Truth in Lending Act (P.L. 90-321) (Regulation Z); Financial Stability Oversight Council and the designation of Nonbank Financial Firms as systemically important; Federal Reserve Systems Large Institution Supervision Coordinating Committee; potential housing finance reform legislation; enforcement of Securities and Exchange Commission penalties; potential repeal of the State and Local Tax (SALT) Cap; federal interest rate authority; Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) reform; electronic consent-based SSN Verification Service (eCBSV); environmental, social, and governance (ESG) enforcement; information Collection under the Community Reinvestment Act (CRA) (P.L. 95-128); potential Financial Transaction Tax (FTT); potential Treasury Department proposal relating to tax reporting by banks; investment company cross trading; potential money market fund reform measures; resolutions to establish task forces on Artificial Intelligence and Financial Technology in the House Committee on Financial Services; transition to the secured overnight financing rate; implementation of SEC Rule 15c2-11; Department of Labor fiduciary advice exemption: PTE 2020-02; benefits of risk-based pricing; mobile disclosures; Federal Trade Commission issues: Freedom of Information Act Requests, Penalty Offense Authority, Zombie Voting, and overall direction of the Commission under Chair Lina Khan; Tax Reporting Proposal by the Department of the Treasury related to a $600 or more annual account threshold; Amendment to the FY22 National Defense Authorization Act related to credit reporting; Climate-Related Financial Risk Management for Large Banks; House Committee on Financial Services request for information related to Russia sanctions; Proposed Rule, Securities and Exchange Commission; Prohibition Against Fraud, Manipulation, or Deception in Connection with Security-Based Swaps, Prohibition against Undue Influence over Chief Compliance Officers, Position Reporting of Large Security-Based Swap Positions; Consumer Financial Protection Bureau (CFPB) activities, including a regulatory sandbox for disclosures; CFPB Policy Fellowship program; CFPB amendment of its Supervision and Examination Manual; CFPB conflation of Distinct Statutory Concepts of Unfairness and Discrimination Promoting the importance of appropriate length of SEC Comment Periods; EU sustainable finance action plan and incorporating ESG factors into financial services; EU review of Alternative Investment Fund Managers Directive; EU review of prudential regime for investment firms; implementation and enforcement of Regulation Best Interest by the Securities and Exchange Commission; changes in the enforcement policies of the Securities and Exchange Commission; activity of the Financial Stability Oversight Council and recommendations on macro-prudential regulation; clarification in the regulatory treatment of digital assets by the Securities and Exchange Commission and the Commodity Futures Trading Commission; implementation and enforcement of proxy advisory firm regulations finalized in 2020; implementation and enforcement of SEC 14a-8 shareholder proposal process reforms finalized in 2020; EU Money Market Fund Regulation, legislative review; electronic delivery of certain investment documents and disclosures; implementation of beneficial ownership reporting requirements under the National Defense Authorization Act FY2021 (P.L. 116-283); implementation of the Social Security Administrations Electronic Consent Based Social Security Number Verification System Service; Financial Stability Board recommendations on money market fund reform; IOSCO recommendations on sustainability-related practices, polices, procedures, and disclosure in asset management; Office of Financial Research (OFR) discussions on FSOC Report on Climate-Related Financial Risk; staff legal guidance at the SEC concerning no-action letters on shareholder proposals with broad societal impact (Staff Legal Bulletin 14L-CF); SEC reforms to regulations related to climate disclosures; SEC reforms to regulations related to Shareholder Proposals; SEC reforms to regulations related to Cybersecurity Disclosures; SEC reforms to regulations related to Human Capital Management Disclosures; SEC reforms to regulations related to Share Repurchase Disclosures; SEC reforms to regulations related to 10b5-1 Disclosure; SEC request for information on digital engagement practices; FinCEN Implementation of the Beneficial Ownership Requirements of the Corporate Transparency Act (P.L. 116-283); SEC Reopening of Comment Period on Pay Versus Performance; SEC Proposed Rule amending 10b5-1; SEC Amended Rule 15c2-11, applicability to 144A securities; SEC Proposed Rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors; SEC prosed rule on private fund advisors; documentation of registered investment adviser compliance reviews; Proposed Rule, Securities and Exchange Commission; Share Repurchase Disclosure Modernization; Proposed Rule, Securities and Exchange Commission; The Enhancement and Standardization of Climate-Related Disclosures for Investors; Proposed Rule, Securities and Exchange Commission; Money Market Fund Reforms; Proposed Rule, Securities and Exchange Commission; Share Repurchase Disclosure Modernization; Notice, Internal Revenue Service; Priority Guidance Plan; Compliance Assistance Release, Department of Labor; 401(k) Plan Investments in Cryptocurrencies Request for Information, Consumer Financial Protection Bureau; Fees Imposed by Providers of Consumer Financial Products or Services; cybersecurity risk management and incident reporting; enhancement and standardization of climate related disclosures to investors SEC regulation

Client expense: $15,800,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

H.R. 1270, Prohibit Auto Insurance Discrimination (PAID) Act H.R. 4277, Overdraft Protection Act of 2021 H.R. 5911, Fair Hiring in Banking Act H.R. 6814, Small Business Fair Debt Collection Protection Act H.R. 7412, Transparency in CFPB Cost-Benefit Analysis Act S. 2417, Credit Access and Inclusion Act of 2021 S. 2508, Veterans and Consumers Fair Credit Act S. 3056, Prohibiting IRS Financial Surveillance Act S. 3755, Arbitration Fairness for Consumers Act Draft legislation titled Ensuring Diversity in Community Banking Act Draft legislation titled Expanding Opportunity for MDIs Act Draft legislation to create a government-run credit bureau at the Consumer Financial Protection Bureau Draft legislation to provide a right of removal to federal court from administrative adjudication Nomination of Sarah Bloom Raskin, Vice Chair for Supervision, Federal Reserve Proposed rule regarding reinstatement of HUDs discriminatory effects standard (86 Fed. Reg. 33,590-33,597, June 25, 2021) FinCEN proposed rule on Beneficial Ownership Reporting Requirements (86 Fed. Reg. 69,920-69,974, December 8, 2021) Proposed Interagency Guidance on Third-Party Relationships: Risk Management (86 Fed. Reg. 38,182-38,204, July 19, 2021); Rulemaking to implement Section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (86 Fed. Reg. 56,356-56,606, October 8, 2021); Various issues relating to structure and independence of the Consumer Financial Protection Bureau; artificial intelligence and machine learning; DOJ Bank Merger Competitive Analysis; OCC Request for Feedback on Principles for Climate-Related Financial Risk Management for Large Banks; FinCEN RFI on Review of Bank Secrecy Act Regulations and Guidance; FDIC Request for Information on Climate-Related Financial Risk Management for Large Institutions; FDIC Request for Comment on Rules, Regulations, Guidance, and Statement of Policy on Bank Merger Transactions

Client expense: $15,800,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Justice, Dept of (DOJ), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of

Legislative proposals impacting banking services for financial services providers; Payday, Vehicle Title, and Certain High-Cost Installment Loans; Federal policy relating to anticipated Consumer Financial Protection Bureau regulation of consumer financial services including payday and auto title lending, and regulatory process; FY2023 National Defense Authorization Act (H.R.7900); H.R.4395, Payment Choice Act of 2021; S.2349, Protecting Consumers from Unreasonable Credit Rates Act of 2021; S.2508/H.R.5974, Veterans and Consumers Fair Credit Act; H.R.2543, Federal Reserve Racial and Economic Equity Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to banking regulatory reform: -HR 1319 American Rescue Plan (Public Law No: 117-2) Implementation -HR 1277/S 374 Improving Corporate Governance Through Diversity Act of 2021 -HR 4258 To establish a governmentwide approach to improving digital identity, and for other purposes. -Issues related to arbitration -Issues related to interest rate caps -HR 745 Fair Access to Credit Act of 2021 -HR 4350 National Defense Authorization Act for Fiscal Year 2022 (issues related to banking) -Issues related to credit scores -HR 1491 Fair Debt Collection Practices for Servicemembers Act -HR 1645 To amend the Fair Credit Reporting Act to make improvements to the regulation of consumer reporting agencies and protect consumers, and for other purposes. -HR 745 Fair Access to Credit Scores Act of 2021 -HR 166 Fair Lending for All Act -HR 5376 Build Back Better Act -HR 5974/S 2508 Veterans and Consumers Fair Credit Act -Issues related to unfair, deceptive, and abusive acts and practices -Issues related to financial innovation -Issues related to financial literacy -Issues related to the Community Reinvestment Act -Issues related to debt collection -Issues related to artificial intelligence -Issues related to small business data collection -Issues related to privacy -HR 8152 American Data Privacy and Protection Act -S 4356 Lummis-Gillibrand Responsible Financial Innovation Act -Issues related to diversity, equity, and inclusion -Issues related to anti-trust -Issues related to fees -Issues related to climate -Issues related to digital assets

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

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), SENATE, Treasury, Dept of

Federal policy relating to anticipated Consumer Financial Protection Bureau regulation of consumer financial services including payday lending, auto title lending, and regulatory process. Potential legislation to regulate interest rates on financial products. S.J. Res. 15 - A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders." Implementation of the CARES Act (PL 116-136), provisions relating to the payroll protection program. Implementation of the American Rescue Plan Act of 2021 (PL-117-2), provisions relating to the payroll protection program. Legislative proposals relating to prohibiting retail businesses from refusing cash payments. H.R. 2040, The Financial Reporting Threshold Modernization Act, provisions relating to updating thresholds for certain currency transaction reports and suspicious activity reports. H.R. 1996, The SAFE Banking Act of 2021, provisions relating to the provision of financial services to cannabis-related businesses and service providers S. 563, The Fair Access to Banking Act, provisions relating to fair access to financial services and discount window lending programs. Veterans and Consumers Fair Credit Act (H.R. 5974/S. 2508), provisions relating to regulation of interest rates on financial products.

Client expense: Not reported · Firm income: $50,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

General issues related to indirect auto financing, S. 2508 and H.R. 5974, Veterans and Consumers Fair Credit Act.

Client expense: Not reported · Firm income: $50,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to the regulation of insurance products and voluntary protection products. Issues related to S. 2508/H.R. 5974, The Veterans and Consumers Fair Credit Act.

Client expense: Not reported · Firm income: $40,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Met with House and Senate on issues impacting GSIBs Met with House and Senate on Fintech charters and issues Met with House and Senate on industrial loan corporations Met with House and Senate on equity market structure Met with House and Senate on climate issues Met with House and Senate staff on cybersecurity issues Met with House on racial equity and diversity inclusion issues Met with House and Senate on digital assets and crypto Met with House and Senate on sanctions legislation Met with House and Senate on markets regulations S.2349, Protecting Consumers from Unreasonable Credit Rates Act of 2021 - all provisions S.2508, Veterans and Consumers Fair Credit Report - all provisions S.3755, Arbitration Fairness for Consumers Act - all provisions S.3844, Economic Continuity and Stability Act - all provisions H.R.963, Forced Arbitration Injustice Repeal Act - all provisions H.R.4616, the Adjustable Interest Rate (LIBOR) Act of 2021 - all provisions

Client expense: $1,370,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE