Stop Overdraft Profiteering Act of 2021

Bank On Central Bank Digital Currency Cryptocurrency Deposit Insurance Digital Assets Nominations Bank Capital Requirements/Basel Capital Proposal Postal Banking S.1323 & H.R.2891, Secure and Fair Enforcement (SAFE) Banking Act of 2023 H.R. 4177 & S. 2007, Improving Corporate Governance Through Diversity Act of 2023 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 758, Promoting Access to Capital in Underbanked Communities Act of 2023 H.R.4590, Promoting New and Diverse Depository Institutions Act H.R. 1533, Promoting New and Diverse Depository Institutions Act Emergency Capital Investment Issues for CDFI and MDI 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. 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. UDAAP Supervisory Policies and Adjudication Procedures Community Reinvestment Act modernization Deposit Insurance Assessment Rates S.1838, Credit Card Competition Act of 2023 H.R. 3881, Credit Card Competition Act of 2023 S.4760, Digital Commodities Consumer Protection Act of 2022 Merchant Category Codes S.1790, Failed Bank Executives Clawback Act S.293 & H.R. 2743, Fair Access to Banking Act H.R. 2799, Expanding Access to Capital Act of 2023 H.R. 2603, To require the Securities and Exchange Commission to revise certain thresholds related to smaller reporting companies, accelerated filers, and large accelerated filers, and for other purposes H.R. 2798, Consumer Financial Protection Bureau Transparency and Accountability Reform Act H.R. 1382, TABS Act of 2023 H.R. 1411, Consumer Financial Protection Bureau-Inspector General Reform Act H.R. 2489, the Consumer Financial Protection Bureau Dual Mandate and Economic Analysis Act H.R. 1313, the Transparency in Consumer Financial Protection Bureau Cost-Benefit Analysis Act H.R. 1719, Making the Consumer Financial Protection Bureau Accountable to Small Business Act S.1362, the Transparency in Consumer Financial Protection Bureau Cost-Benefit Analysis Act H.R. 490, Federal Infrastructure Bank Act of 2023 H.R. 4868, Member Business Loan Expansion Act H.R. 4035, Protecting Small Business Information Act of 2023 S.2760, Capping Credit Card Interest Rates Act H.R. 5485, Financial privacy Act of 2023 H.R. 5524, Foreign Affiliate Sharing Pilot Program H.R. 5403, Central Bank Digital Currency Anti-Surveillance Act H.R. 5741, Uniform Treatment of Custodial Assets Act S. 2860, Secure and Fair Enforcement Regulation (SAFER) Banking Act H.R. 4763, Financial Innovation and Technology for the 21st Century Act H.R. 4766, Clarity for Payment Stablecoins Act of 2023 S. 2190, Recovering Executive Compensation Obtained Through Unaccountable Practices (RECOUP) Act of 2023 S. 2251, Federal Information Security Modernization Act H.R. 3398, Safe Access to Cash Act of 2023 S. 3549, the Predatory Lending Elimination Act H.R. 6789, Rectifying UDAAP Act H.R. 1810, Bank Loan Privacy Act H.R. 1806/S. 1159, Small Lender Act H.R. 4346, Small Bank Holding Company Relief Act of 2023 H.R. 4198, Protecting Consumers from Abusive Mortgage Leads Act S. 3502, Homebuyers Privacy Protection Act Regulation II: Debit Card Interchange Fees and Routing Implementation of Dodd-Frank Act Section 1033-- Proposed Rule on Personal Financial Data Rights Department of Labor Retirement Security Rule: Definition of an Investment Advice Fiduciary (Fiduciary Rule) S.3554, Financial Artificial Intelligence Risk Reduction Act CDFI Certification Update

Client expense: $1,910,000 · Firm income: Not reported

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

Bank On Central Bank Digital Currency Cryptocurrency Deposit Insurance Digital Assets Nominations Bank Capital Requirements Postal Banking S.1323 & H.R.2891, Secure and Fair Enforcement (SAFE) Banking Act of 2023 H.R. 4177& S. 2007, Improving Corporate Governance Through Diversity Act of 2023 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 758, Promoting Access to Capital in Underbanked Communities Act of 2023 H.R.1533, Promoting New and Diverse Depository Institutions Act Emergency Capital Investment Issues for CDFI and MDI 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.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. UDAAP Supervisory Policies and Adjudication Procedures Community Reinvestment Act modernization Deposit Insurance Assessment Rates S.1838, Credit Card Competition Act H.R. 3881, Credit Card Competition Act S.4760, Digital Commodities Consumer Protection Act of 2022 Merchant Category Codes S.1790--Failed Bank Executives Clawback Act S.293 & H.R. 2743, Fair Access to Banking Act H.R. 2799, Expanding Access to Capital Act of 2023 H.R. 2603, To require the Securities and Exchange Commission to revise certain thresholds related to smaller reporting companies, accelerated filers, and large accelerated filers, and for other purposes H.R. 2798 Consumer Financial Protection Bureau Transparency and Accountability Reform Act H.R.1382 TABS Act of 2023 H.R.1411, Consumer Financial Protection Bureau-Inspector General Reform Act H.R. 2489, the Consumer Financial Protection Bureau Dual Mandate and Economic Analysis Act H.R.1313, the Transparency in Consumer Financial Protection Bureau Cost-Benefit Analysis Act H.R.1719, Making the Consumer Financial Protection Bureau Accountable to Small Business Act S.1362, the Transparency in Consumer Financial Protection Bureau Cost-Benefit Analysis Act H.R. 490, Federal Infrastructure Bank Act of 2023 H.R. 4868, Member Business Loan Expansion Act H.R. 4035, Protecting Small Business Information Act of 2023 S.2760, Capping Credit Card Interest Rates Act H.R. 5485, Financial privacy Act of 2023 H.R. 5524, Foreign Affiliate Sharing Pilot Program H.R. 5403, Central Bank Digital Currency Anti-Surveillance Act H.R. 5741, Uniform Treatment of Custodial Assets Act S.2860, Secure and Fair Enforcement Regulation (SAFER) Banking Act H.R. 4763, Financial Innovation and Technology for the 21st Century Act H.R. 4766, Clarity for Payment Stablecoins Act of 2023 S.2190, Recovering Executive Compensation Obtained Through Unaccountable Practices (RECOUP) Act of 2023 S. 2251, Federal Information Security Modernization Act H.R. 3398, Safe Access to Cash Act of 2023

Bank On Central Bank Digital Currency Cryptocurrency Digital Assets Market Structure Bill (Draft) A Bill to Provide for the Regulation of Payment Stablecoins (Draft) Nominations Postal Banking S.1323 & H.R.2891, Secure and Fair Enforcement (SAFE) Banking Act of 2023 H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 758, Promoting Access to Capital in Underbanked Communities Act of 2023 H.R.1533, Promoting New and Diverse Depository Institutions 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 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. UDAAP Supervisory Policies and Adjudication Procedures Community Reinvestment Act Deposit Insurance Assessment Rates S.1838 , Credit Card Competition Act H.R. 3881, Credit Card Competition Act S.4760, Digital Commodities Consumer Protection Act of 2022 Merchant Category Codes S.1790--Failed Bank Executives Clawback Act S.293 & H.R. 2743, Fair Access to Banking Act H.R. 2799, Expanding Access to Capital Act of 2023 H.R. 2603, To require the Securities and Exchange Commission to revise certain thresholds related to smaller reporting companies, accelerated filers, and large accelerated filers, and for other purposes H.R.2798 Consumer Financial Protection Bureau Transparency and Accountability Reform Act H.R.1382 TABS Act of 2023 H.R.1411, Consumer Financial Protection Bureau-Inspector General Reform Act H.R. 2489, the Consumer Financial Protection Bureau Dual Mandate and Economic Analysis Act H.R.1313, the Transparency in Consumer Financial Protection Bureau Cost-Benefit Analysis Act H.R.1719, Making the Consumer Financial Protection Bureau Accountable to Small Business Act S.1362, the Transparency in Consumer Financial Protection Bureau Cost-Benefit Analysis Act H.R.490, Federal Infrastructure Bank Act of 2023

Bank On Buy Now, Pay Later Central Bank Digital Currency Cryptocurrency Digital Assets Nominations USPS Pilot Banking Program H.R. 1996, The SAFE Banking Act H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 758, Promoting Access to Capital in Underbanked Communities Act of 2023 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.1533, Promoting New and Diverse Depository Institutions 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 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. 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 S.4760, Digital Commodities Consumer Protection Act of 2022 Merchant Category Codes

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.

Issues related to H.R. 5376 (the Inflation Reduction Act), S. 2677, and H.R. 5024 (To amend the Internal Revenue Code of 1986 to allow for payments to certain individuals who dye fuel, and for other purposes).

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

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

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

H.R. 4277 S.2677 Would implement highly prescriptive disclosures, limitations, and prohibitions on a financial products that are in high demand by consumers who can opt- out of services H.R. 6889 S. 4325 Allows credit union boards to meet every other month rather than every month provided that the credit union is in good standing H.R. 1996 S. 910 Allows financial institutions to provide banking services to marijuana businesses in states where it has been legalized H.R. 8152 Would implement one national standard for all holders of financial information including merchants. H.R. 2543 S.1327 add underserved areas to the field of membership exempt business loans made to businesses located in underserved areas from the member business lending cap

Client expense: Not reported · Firm income: $9,000

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.

Lobbied Congress on the Overdraft Protection Act (H.R.4277), the Stop Overdraft Profiteering Act (S.2677), and amending the Electronic Funds Transfer Act (EFTA) to protect consumers from peer-to-peer payment app fraud. Attended a coalition meeting with CFPB Director Chopra on a wide range of issues. 28 Sept Presented views on Consumer Financial Protection Act Section 1033 in group meeting with CFPB director 10 Aug Meet w/ senior CFPB staff on digital issues 5 Aug - Joined consumer groups in comment letter to Treasury Department re ensuring responsible development of digital assets. Docket TREAS-DO-2022-0014-0001. 2 Aug Meet w/ senior CFPB staff on relationship banking 28 July Joined group meeting w/ CFPB director on privacy and banking 25 July Joined consumer groups in letter to House Financial Services Committee supporting HR4277, the Overdraft Protection Act. 22 July Met with House Financial Services Committee staff on Overdraft Protection HR 4277 21 July Met with House Financial Services Committee staff on relationship between Gramm-Leach-Bliley Act of 1999 and HR8152, the American Data Privacy Protection Act of 2022

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

Issues related to H.R. 5376 (the Inflation Reduction Act, formerly referred to as the Build Back Better Act), S. 2677 (Stop Overdraft Profiteering Act of 2021), and H.R. 5024 (To amend the Internal Revenue Code of 1986 to allow for payments to certain individuals who dye fuel, and for other purposes).

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

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

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

Financial Services General Government Appropriations (H.R.8254/S.4685) Overdraft Protection Act (H.R.4277) Stop Overdraft Protection Act (S.2677)

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

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

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

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 will continue to educate our delegation members on the importance of interchange and harms that would be caused by expanding it. 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.

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

Overdraft Protection Act of 2021 (H.R.4277/S.2677) Servicemembers Safety and Security Act of 2021 (H.R.3769/S.2058) SMART Act of 2021 (S.2801) Veterans and Consumers Fair Credit Act (H.R.5974/S.2508)

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

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 Restore the 2017 payday loan rule and supervise the larger installment, line of credit and vehicle title lenders, especially high-cost lenders Eliminating excessive banking fees, including overdraft Data-driven technologies, including algorithmic decision making, artificial intelligence, and machine learning CFPB's online complaint system acess for consumers with Limited English Proficiency Lender robosigning on collections for consumer credit Treatment of new and existing Industrial Loan Corporations 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 HR. 2547 - Comprehensive Debt Collection Improvement Act, a bill to provide additional financial protections for consumers and places restrictions on debt collection activities Nominations for FRB

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

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 will continue to educate our delegation members on the importance of interchange and harms that would be caused by expanding it. 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.

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

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 will continue to educate our delegation members on the importance of interchange and harms that would be caused by expanding it. 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.

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