Postal Police Reform Act of 2023

H.R. 130/S. 459, the Thin Blue Line Act, which would expand the list of statutory aggravating factors in death penalty determinations to also include killing or targeting a law enforcement officer, firefighter, or other first responders; H.R. 233, which would codify the existing qualified immunity doctrine as established and upheld by the U.S. Supreme Court; H.R. 304, the Stop Enabling Repeat Violence and Endangering (SERVE) Our Communities Act, which would establish an annual grant program for State and local governments to fund programs like transitional services, mentoring, and job training for young offenders; H.R. 355, the Back the Blue Act, which would improve protections for law enforcement officers by increasing the penalties for those who kill or assault law enforcement officers, impose time and other limits on Federal courts review of habeas corpus, amend the Law Enforcement Officers Safety Act (LEOSA), and provide new grants; H.R. 472/S. 645, the Fighting Post-Traumatic Stress Disorder Act, which directs the U.S. Department of Justice to develop a state-of-the-art treatment program for public safety officers experiencing acute stress disorder, post-traumatic stress disorder (PTSD), or similar conditions; H.R. 743, the Protect and Serve Act, which would make it a Federal crime to target a law enforcement officer with an assault that results in serious bodily harm or death; H.R. 795/S. 261, the Protecting First Responders from Secondary Exposure Act, would allow State and local governments to purchase containment devices through the existing Comprehensive Opioid, Stimulant, and Substance Abuse Program (COSSAP); H.R. 898/S. 546, the Recruit and Retain Act, which would authorize COPS grantees to use grant funds for the recruitment and retention of law enforcement officers; H.R. 1005, the EAGLES Act, which would reauthorize and expand the National Threat Assessment Center (NTAC) within the U.S. Department of Homeland Security; H.R. 1105, the Debbie Smith Reauthorization Act, which would reauthorize the Debbie Smith Act for five years and allocate $151 million in funding; H.R. 1649, the Establishing Accreditation Grants for Law Enforcement (EAGLE) Act, which would establish a grant program that would pay the certification or re-certification fees for small to mid-size agencies that have fewer than 350 employees; H.R. 1719, the Honoring Our Fallen Heroes Act, which would categorize duty-related cancer fatalities as a line of duty death under Public Safety Officers Benefits program; H.R. 1839/S. 993, the Combating Illicit Xylazine Act, which would add xylazine to the Controlled Substances Act, listing it as a Schedule III drug for illicit use; H.R. 2548, the Public Safety Concussions and Traumatic Brain Injury Health Act, which would direct the CDC to expand their data collection efforts, publicly release their findings, and suggest protocols to prevent instances of Traumatic Brain Injuries for Law Enforcement; H.R. 2601, the National Human Trafficking Hotline Enhancement Act, which would require the full cooperation of any grant recipient that contracts with the Administration for Children and Families (ACF) at the U.S. Department of Health and Human Services to operate the National Human Trafficking Hotline, sharing information and assisting efforts by State and local law enforcement to combat human trafficking; S. 2644, the American Law Enforcement Sustaining Aid and Vital Emergency Resources (SAVER) Act," which would expand the existing Edward Byrne Memorial Justice Assistance Grant (Byrne-JAG) program to allow for the purchase of trauma kits; H.R. 2722/S.3554, the Providing Child Care to Police Officers Act, which would establish a grant pilot program to provide child care services for the minor children of law enforcement officers to accommodate the shift work and abnormal work hours of such officers, and to enhance recruitment and retention of such officers; H.R. 2949, the Public Service Loan Forgiveness (PSLF) Payment Completion Fairness Act, which would aid our nations public servants, including law enforcement officers, firefighters, and first responders, by forgiving the remaining balance of their Federal direct student loans after ten years of qualifying public service and payments; H.R. 3005/S.3356, the Postal Police Reform Act," which would reverse a 2020 directive from the United States Postal Service (USPS) that bans postal police from performing their patrol duties outside of real estate owned or leased by the postal service. Prior to this directive, the postal police additionally had jurisdiction over all postal service property and were authorized to protect mail carriers, collection boxes, and vehicles; H.R. 3150, the Overcoming Prevalent Inadequacies in Overdose Information Data Sets (OPIOIDS) Act., which would empower the Attorney General to award grants to local law enforcement departments and forensic laboratories in communities with high rates of drug overdoses; H.R. 3170/S. 1514, the Homes for Every Local Protector, Educator, and Responder (HELPER) Act, which creates a home loan benefits program for first responders and educators based on the successful U.S. Department of Veterans Affairs home loan program available to our nations veterans; H.R. 3269/S. 4255, the Law Enforcement Innovate to De-Escalate Act, which would create a new definition for a less-than-lethal projectile device in Federal firearms law; H.R. 3333/S.1271, the Fentanyl Eradication and Narcotics Deterrence (FEND) Off Fentanyl Act, which would direct the resources of the U.S. government to target the fentanyl supply chain; H.R. 3449, Erics Law, which would allow Federal prosecutors to impanel a second jury for the sentencing phase of a Federal capital case if the first jury does not reach a unanimous decision on the sentence; H.R. 4384, the Project Safe Neighborhoods Grant Program Authorization Act, which would reauthorize critical funding and support for local law enforcement agencies and community organizations that help reduce violent crime and enhance public safety; H.R. 4639, the Fourth Amendment Is Not For Sale Act, which would impose a probable cause standard for certain types of information; H.R. 5029, the Strong Communities Act, which would help build on the community-policing model by establishing a grant program for local law enforcement agencies to assist in recruiting officers from their own community; H.R. 5182, the Child Online Safety Modernization Act, which would strengthen the National Center for Missing and Exploited Children CyberTipline by modernizing and improving the reporting process, extending the required preservation period for individual reports to one year, and replacing the term, child pornography, with child sexual abuse materials throughout all Federal statutes; H.R. 5266, the Interdiction of Fentanyl in Postal Mail at Federal Prisons Act, which would empower the Director of the Bureau of Prisons (BOP) to evaluate correctional facilities capabilities to protect staff and detainees from exposure to synthetic drugs and opioids and implement appropriate protective measures as a result of the findings; H.R. 5538, the Border Patrol Pay Fix Act, which would allow the majority of Border Patrol agents to receive a special overtime pay rate; H.R. 5798, the Protecting Our Nations Capital Emergency Act, which would undue certain provisions of the Comprehensive Policing and Justice Reform Amendment Act (CPJRAA) passed by the Washington D.C. City Council; H.R. 6246, the Eliminate Network Distribution (END) of Child Exploitation Act, which would improve the effectiveness of the CyberTipline, the nations centralized reporting system for the online exploitation of children; H.R. 6688, the Cold Case Modernization Act, which will extend DOJ grant funding for forensic genetic genealogy (FGG) testing to cover the identification process of all unidentified human remains, without regard to the manner of their death; H.R. 7185, the HIDTA Reauthorization Act., which would reauthorize the High Intensity Drug Trafficking Areas Program; H.R. 7456, the "First Responders Emergency Assistance Act.", which would establish additional grants through the Department of Homeland Security to law enforcement agencies within 100 miles of the U.S.-Mexico Border; H.R. 7487, the Assisting Narcotics and Trafficking Officers in Interdicting (ANTI) Drugs Act., which would allocate $400 million to the High Intensity Drug Trafficking Areas (HIDTA) program under the Office of National Drug Control Policy. H.R. 7720(Kean, R-NJ), which would allow grant funds from the Edward Byrne Memorial Justice Assistance Grant (Byrne-JAG) to be used for the purchase of fentanyl testing kits and opioid reversal agents; H.R. 7730 (Spanberger, D-VA), directing the GAO to investigate the methods used to enable such online sales and assess the procedures and efforts of Federal law enforcement and online providers in combatting online sales of fentanyl; H.R. 7456 (Duarte, R-CA) the First Responders Emergency Assistance Act., which would establish additional grants through the Department of Homeland Security to law enforcement agencies within 100 miles of the U.S.-Mexico Border; H.J. Res. 42/S.J. Res. 26, a resolution disapproving the adoption of the Comprehensive Policing and Justice Reform Amendment Act (CPJRAA) by the Washington, D.C. City Council; H. Res. 285, a resolution calling on Congress to respect the rights of law enforcement officers and establish a Bill of Rights for them; S. 474, the Revising Existing Procedures on Reporting via Technology (REPORT) Act, which would provide the CyberTipline, a critical tool for law enforcement run by the National Center for Missing and Exploited Children, the necessary resources and infrastructure needed to protect children from digital exploitation; S. 499, the Debbie Smith Reauthorization Act, which would reauthorize the Debbie Smith Act for five years and allocate $151 million in funding; S. 529, Erics Law, which would allow Federal prosecutors to impanel a second jury for the sentencing phase of a Federal capital case if the first jury does not reach a unanimous decision on the sentence; S.894, the Public Safety Concussions and Traumatic Brain Injury Health Act, which would help law enforcement agencies establish concussion and traumatic brain injury (TBI) protocols; S. 930, the Honoring Our Fallen Heroes Act, which would categorize duty-related cancer fatalities as a line of duty death under Public Safety Officers Benefits program; S. 972/H.R. 8420, the Filling Public Safety Vacancies Act, which provides a one-time boost of $162 million for the hiring program administered by the Office of Community Oriented Policing Services (COPS); S. 994, the Strong Communities Act, which would help build on the community-policing model by establishing a grant program for local law enforcement agencies to assist in recruiting officers from their own community; H.R. 8918/S. 1080, the Cooper Davis Act, which would require social media providers to report all suspected illicit drug activity occurring on their platforms to the Drug Enforcement Agency (DEA); S. 1170, Project Safe Childhood, which updates and expands provisions included in the original Project Safe Childhood initiative launched by the U.S. Department of Justice (DOJ); S. 1199, Strengthening Transparency and Obligation to Protect Children Suffering from Abuse and Mistreatment (STOP CSAM) Act, which provides special privacy protections to certain child victims and witnesses in criminal prosecutions; S. 1207, the Eliminating Abusive and Rampant Neglect of Interactive Technologies (EARN IT) Act, which would establish a National Commission on Online Child Sexual Exploitation Prevention in an effort to combat the sexual exploitation of children on the Internet; S. 1306, the COPS Reauthorization Act, which will reauthorize the Office of Community Oriented Policing Services (COPS) and all the programs it administers through 2029; S. 1331, the Public Service Loan Forgiveness (PSLF) Payment Completion Fairness Act, which would aid our nations public servants, including law enforcement officers, firefighters, and first responders, by forgiving the remaining balance of their Federal direct student loans after ten years of qualifying public service and payments; S. 1387, the Project Safe Neighborhoods Grant Program Authorization Act, which would reauthorize critical funding and support for local law enforcement agencies and community organizations that help reduce violent crime and enhance public safety; S. 1447, the Bipartisan Solution to Cyclical Violence Act, which would authorize the U.S. Secretary of Health and Human Services (HHS) to select existing violence prevention or intervention programs, administered by State and local trauma centers, to receive Federal grants to expand existing programs, study the effectiveness of those programs, and examine their impacts on reincarceration and re-admittance rates; S. 1507, the Providing Officers with Electronic Resources (POWER) Act, which establishes a grant program within the Office of Community Oriented Policing Services (COPS) to aid State and local law enforcement in obtaining portable chemical screening devices to identify the substances they encounter daily; S. 1530, the COPS on the Beat Grant Program Parity Act, which allows underserved and rural communities greater flexibility to use COPS grants to raise law enforcement salaries to help retain good officers and improve recruitment efforts; S. 1569, the Back the Blue Act. which improves protections for law enforcement officers by increasing the penalties for those who kill or assault law enforcement officers, judges, and other public safety officers; S. 1857, the Assisting Narcotics and Trafficking Officers in Interdicting (ANTI) Drugs Act, which would reauthorize, and increase funding for, Operation Stonegarden; S. 2313, the Driving for Opportunity Act, which would create a grant program for States to reinstate drivers licenses that were suspended for unpaid fines and fees; S. 2567, the Stop Computer Crimes Proliferation Act, which would reauthorize the programs in the Computer Crime Enforcement Act; S. 2569, the "Fentanyl Safe Testing and Overdose Prevention Act". which would amend the Controlled Substances Act to clarify that the possession, sale, purchase, importation, exportation, or transportation of drug testing equipment that tests for the presence of fentanyl or xylazine is not unlawful; S. 2596, the Kenneth P. Thompson Begin Again Act, would amend current law (18 U.SC. 3607) expunging an individuals minor possession offense if the individual meets the laws stringent requirements. This legislation amends this rule, eliminating the age requirement; S. 2637/H.R. 8871, the Law Enforcement Scenario-Based Training for Safety and De-Escalation Act, which would direct the Office of Community Oriented Policing Services (COPS) to authorize grants to State, and local law enforcement agencies to provide law enforcement personnel access to an immersive, real-life, scenario-based training curriculum which will improve community-police relations, as well as officer safety and resilience; S. 2644, the American Law Enforcement Sustaining Aid and Vital Emergency Resources (SAVER) Act, would expand the existing Edward Byrne Memorial Justice Assistance Grant (Byrne-JAG) program to allow for the purchase of trauma kits; S.3522, the Improving Law Enforcement Officer Safety and Wellness Through Data Act, which would require the Attorney General to develop reports relating to violent attacks against law enforcement officers, and for other purposes; S. 3643, the Combating Money Laundering, Terrorist Financing, and Counterfeiting Act, which would update current law concerning hawala and other informal value transfer systems like those used by international terrorists and trafficking organizations, additionally, purposes to double the penalties for those who violate bulk-cash smuggling laws; S. 3763, the Violent Incident Clearance and Technological Investigative Methods (VICTIM) Act, which would establish a grant program administered by the U.S. Department of Justice (DOJ) to help State, Tribal, and local law enforcement agencies improve their clearance rates for homicides and firearm-related violent crimes; S. 4450 (Kelly D-AZ), the Educational and Career Opportunities for Public Safety Act, which would offer officers financial assistance for higher education for those who have served for a period of eight years with the same agency and who are willing to commit to serving at least an additional four.

Client expense: $75,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Justice, Dept of (DOJ), SENATE, White House Office

H.R. 595, the Postal Supervisors and Managers Fairness Act, legislation to provide a reasonable timeline for pay consultations between the U.S. Postal Service and the managerial organization representing postal supervisors, managers and postmasters H.R. 595, the Postal Employees Appeal Rights Amendment Act, legislation to provide all Executive Administrative Schedule (EAS) level postal employees the right to appeal adverse actions to the Merit Systems Protection Board H.Con.Res. 277, a House resolution restore postal delivery standards to the level provided in 2012 H.R. 3005/S. 3356, Postal Police Reform Act, legislation to clarify that USPS police offices have law enforcement authority beyond the perimeter of a postal facility H.R. 3721, USPS Shipping Equity Act, legislation to permit the USPS to transport alcoholic beverages in accordance with federal and state laws PI2003-4, Postal Regulatory Commission Docket related to implementation of USPS' 10-year strategic plan ACR2023, Postal Regulatory Commission Annual Compliance Review HR 7629, Protect Our Letter Carrier Act, legislation to require Department of Justice to designate Assistant US Attorneys for postal-related crimes, authorize increase penalties for certain postal-related crimes, and authorize funds to replace postal keys. Legislation relating to closure and/or consolidation of postal facilities. Legislation relating to improving postal performance and speed of mail delivery.

Client expense: $26,250 · Firm income: Not reported

H.R. 130/S. 459, the Thin Blue Line Act, which would expand the list of statutory aggravating factors in death penalty determinations to also include killing or targeting a law enforcement officer, firefighter, or other first responders; H.R. 233, which would codify the existing qualified immunity doctrine as established and upheld by the U.S. Supreme Court; H.R. 304, the Stop Enabling Repeat Violence and Endangering (SERVE) Our Communities Act, which would establish an annual grant program for State and local governments to fund programs like transitional services, mentoring, and job training for young offenders; H.R. 355, the Back the Blue Act, which would improve protections for law enforcement officers by increasing the penalties for those who kill or assault law enforcement officers, impose time and other limits on Federal courts review of habeas corpus, amend the Law Enforcement Officers Safety Act (LEOSA), and provide new grants; H.R. 472/S. 645, the Fighting Post-Traumatic Stress Disorder Act, which directs the U.S. Department of Justice to develop a state-of-the-art treatment program for public safety officers experiencing acute stress disorder, post-traumatic stress disorder (PTSD), or similar conditions; H.R. 743, the Protect and Serve Act, which would make it a Federal crime to target a law enforcement officer with an assault that results in serious bodily harm or death; H.R. 795/S. 261, the Protecting First Responders from Secondary Exposure Act, would allow State and local governments to purchase containment devices through the existing Comprehensive Opioid, Stimulant, and Substance Abuse Program (COSSAP); H.R. 898/S. 546, the Recruit and Retain Act, which would authorize COPS grantees to use grant funds for the recruitment and retention of law enforcement officers; H.R. 1005, the EAGLES Act, which would reauthorize and expand the National Threat Assessment Center (NTAC) within the U.S. Department of Homeland Security; H.R. 1105, the Debbie Smith Reauthorization Act, which would reauthorize the Debbie Smith Act for five years and allocate $151 million in funding; H.R. 1649, the Establishing Accreditation Grants for Law Enforcement (EAGLE) Act, which would establish a grant program that would pay the certification or re-certification fees for small to mid-size agencies that have fewer than 350 employees; H.R. 1719, the Honoring Our Fallen Heroes Act, which would categorize duty-related cancer fatalities as a line of duty death under Public Safety Officers Benefits program; H.R. 1839/S. 993, the Combating Illicit Xylazine Act, which would add xylazine to the Controlled Substances Act, listing it as a Schedule III drug for illicit use; H.R. 2548, the Public Safety Concussions and Traumatic Brain Injury Health Act, which would direct the CDC to expand their data collection efforts, publicly release their findings, and suggest protocols to prevent instances of Traumatic Brain Injuries for Law Enforcement; H.R. 2601, the National Human Trafficking Hotline Enhancement Act, which would require the full cooperation of any grant recipient that contracts with the Administration for Children and Families (ACF) at the U.S. Department of Health and Human Services to operate the National Human Trafficking Hotline, sharing information and assisting efforts by State and local law enforcement to combat human trafficking; S. 2644, the American Law Enforcement Sustaining Aid and Vital Emergency Resources (SAVER) Act," which would expand the existing Edward Byrne Memorial Justice Assistance Grant (Byrne-JAG) program to allow for the purchase of trauma kits; H.R. 2722/S.3554, the Providing Child Care to Police Officers Act, which would establish a grant pilot program to provide child care services for the minor children of law enforcement officers to accommodate the shift work and abnormal work hours of such officers, and to enhance recruitment and retention of such officers; H.R. 2949, the Public Service Loan Forgiveness (PSLF) Payment Completion Fairness Act, which would aid our nations public servants, including law enforcement officers, firefighters, and first responders, by forgiving the remaining balance of their Federal direct student loans after ten years of qualifying public service and payments; H.R. 3005/S.3356, the Postal Police Reform Act," which would reverse a 2020 directive from the United States Postal Service (USPS) that bans postal police from performing their patrol duties outside of real estate owned or leased by the postal service. Prior to this directive, the postal police additionally had jurisdiction over all postal service property and were authorized to protect mail carriers, collection boxes, and vehicles; H.R. 3150, the Overcoming Prevalent Inadequacies in Overdose Information Data Sets (OPIOIDS) Act., which would empower the Attorney General to award grants to local law enforcement departments and forensic laboratories in communities with high rates of drug overdoses; H.R. 3170/S. 1514, the Homes for Every Local Protector, Educator, and Responder (HELPER) Act, which creates a home loan benefits program for first responders and educators based on the successful U.S. Department of Veterans Affairs home loan program available to our nations veterans; H.R. 3269, the Law Enforcement Innovate to De-Escalate Act, which would create a new definition for a less-than-lethal projectile device in Federal firearms law; H.R. 3333/S.1271, the Fentanyl Eradication and Narcotics Deterrence (FEND) Off Fentanyl Act, which would direct the resources of the U.S. government to target the fentanyl supply chain; H.R. 3449, Erics Law, which would allow Federal prosecutors to impanel a second jury for the sentencing phase of a Federal capital case if the first jury does not reach a unanimous decision on the sentence; H.R. 4384, the Project Safe Neighborhoods Grant Program Authorization Act, which would reauthorize critical funding and support for local law enforcement agencies and community organizations that help reduce violent crime and enhance public safety; H.R. 4639, the Fourth Amendment Is Not For Sale Act, which would impose a probable cause standard for certain types of information; H.R. 5029, the Strong Communities Act, which would help build on the community-policing model by establishing a grant program for local law enforcement agencies to assist in recruiting officers from their own community; H.R. 5182, the Child Online Safety Modernization Act, which would strengthen the National Center for Missing and Exploited Children CyberTipline by modernizing and improving the reporting process, extending the required preservation period for individual reports to one year, and replacing the term, child pornography, with child sexual abuse materials throughout all Federal statutes; H.R. 5266, the Interdiction of Fentanyl in Postal Mail at Federal Prisons Act, which would empower the Director of the Bureau of Prisons (BOP) to evaluate correctional facilities capabilities to protect staff and detainees from exposure to synthetic drugs and opioids and implement appropriate protective measures as a result of the findings; H.R. 5538, the Border Patrol Pay Fix Act, which would allow the majority of Border Patrol agents to receive a special overtime pay rate; H.R. 5798, the Protecting Our Nations Capital Emergency Act, which would undue certain provisions of the Comprehensive Policing and Justice Reform Amendment Act (CPJRAA) passed by the Washington D.C. City Council; H.R. 6246, the Eliminate Network Distribution (END) of Child Exploitation Act, which would improve the effectiveness of the CyberTipline, the nations centralized reporting system for the online exploitation of children; H.R. 6688, the Cold Case Modernization Act, which will extend DOJ grant funding for forensic genetic genealogy (FGG) testing to cover the identification process of all unidentified human remains, without regard to the manner of their death; H.R. 7185, the HIDTA Reauthorization Act., which would reauthorize the High Intensity Drug Trafficking Areas Program; H.R. 7456, the "First Responders Emergency Assistance Act.", which would establish additional grants through the Department of Homeland Security to law enforcement agencies within 100 miles of the U.S.-Mexico Border; H.R. 7487, the Assisting Narcotics and Trafficking Officers in Interdicting (ANTI) Drugs Act., which would allocate $400 million to the High Intensity Drug Trafficking Areas (HIDTA) program under the Office of National Drug Control Policy. H.R. 7720(Kean, R-NJ), which would allow grant funds from the Edward Byrne Memorial Justice Assistance Grant (Byrne-JAG) to be used for the purchase of fentanyl testing kits and opioid reversal agents; H.R. 7730 (Spanberger, D-VA), directing the GAO to investigate the methods used to enable such online sales and assess the procedures and efforts of Federal law enforcement and online providers in combatting online sales of fentanyl; H.J. Res. 42/S.J. Res. 26, a resolution disapproving the adoption of the Comprehensive Policing and Justice Reform Amendment Act (CPJRAA) by the Washington, D.C. City Council; H. Res. 285, a resolution calling on Congress to respect the rights of law enforcement officers and establish a Bill of Rights for them; S. 474, the Revising Existing Procedures on Reporting via Technology (REPORT) Act, which would provide the CyberTipline, a critical tool for law enforcement run by the National Center for Missing and Exploited Children, the necessary resources and infrastructure needed to protect children from digital exploitation; S. 499, the Debbie Smith Reauthorization Act, which would reauthorize the Debbie Smith Act for five years and allocate $151 million in funding; S. 529, Erics Law, which would allow Federal prosecutors to impanel a second jury for the sentencing phase of a Federal capital case if the first jury does not reach a unanimous decision on the sentence; S.894, the Public Safety Concussions and Traumatic Brain Injury Health Act, which would help law enforcement agencies establish concussion and traumatic brain injury (TBI) protocols; S. 930, the Honoring Our Fallen Heroes Act, which would categorize duty-related cancer fatalities as a line of duty death under Public Safety Officers Benefits program; S. 972, the Filling Public Safety Vacancies Act, which provides a one-time boost of $162 million for the hiring program administered by the Office of Community Oriented Policing Services (COPS); S. 994, the Strong Communities Act, which would help build on the community-policing model by establishing a grant program for local law enforcement agencies to assist in recruiting officers from their own community; S. 1080, the Cooper Davis Act, which would require social media providers to report all suspected illicit drug activity occurring on their platforms to the Drug Enforcement Agency (DEA); S. 1170, Project Safe Childhood, which updates and expands provisions included in the original Project Safe Childhood initiative launched by the U.S. Department of Justice (DOJ); S. 1199, Strengthening Transparency and Obligation to Protect Children Suffering from Abuse and Mistreatment (STOP CSAM) Act, which provides special privacy protections to certain child victims and witnesses in criminal prosecutions; S. 1207, the Eliminating Abusive and Rampant Neglect of Interactive Technologies (EARN IT) Act, which would establish a National Commission on Online Child Sexual Exploitation Prevention in an effort to combat the sexual exploitation of children on the Internet; S. 1306, the COPS Reauthorization Act, which will reauthorize the Office of Community Oriented Policing Services (COPS) and all the programs it administers through 2029; S. 1331, the Public Service Loan Forgiveness (PSLF) Payment Completion Fairness Act, which would aid our nations public servants, including law enforcement officers, firefighters, and first responders, by forgiving the remaining balance of their Federal direct student loans after ten years of qualifying public service and payments; S. 1387, the Project Safe Neighborhoods Grant Program Authorization Act, which would reauthorize critical funding and support for local law enforcement agencies and community organizations that help reduce violent crime and enhance public safety; S. 1447, the Bipartisan Solution to Cyclical Violence Act, which would authorize the U.S. Secretary of Health and Human Services (HHS) to select existing violence prevention or intervention programs, administered by State and local trauma centers, to receive Federal grants to expand existing programs, study the effectiveness of those programs, and examine their impacts on reincarceration and re-admittance rates; S. 1507, the Providing Officers with Electronic Resources (POWER) Act, which establishes a grant program within the Office of Community Oriented Policing Services (COPS) to aid State and local law enforcement in obtaining portable chemical screening devices to identify the substances they encounter daily; S. 1530, the COPS on the Beat Grant Program Parity Act, which allows underserved and rural communities greater flexibility to use COPS grants to raise law enforcement salaries to help retain good officers and improve recruitment efforts; S. 1569, the Back the Blue Act. which improves protections for law enforcement officers by increasing the penalties for those who kill or assault law enforcement officers, judges, and other public safety officers; S. 1857, the Assisting Narcotics and Trafficking Officers in Interdicting (ANTI) Drugs Act, which would reauthorize, and increase funding for, Operation Stonegarden; S. 2313, the Driving for Opportunity Act, which would create a grant program for States to reinstate drivers licenses that were suspended for unpaid fines and fees; S. 2567, the Stop Computer Crimes Proliferation Act, which would reauthorize the programs in the Computer Crime Enforcement Act; S. 2569, the "Fentanyl Safe Testing and Overdose Prevention Act". which would amend the Controlled Substances Act to clarify that the possession, sale, purchase, importation, exportation, or transportation of drug testing equipment that tests for the presence of fentanyl or xylazine is not unlawful; S. 2596, the Kenneth P. Thompson Begin Again Act, would amend current law (18 U.SC. 3607) expunging an individuals minor possession offense if the individual meets the laws stringent requirements. This legislation amends this rule, eliminating the age requirement; S. 2637, the Law Enforcement Scenario-Based Training for Safety and De-Escalation Act, which would direct the Office of Community Oriented Policing Services (COPS) to authorize grants to State, and local law enforcement agencies to provide law enforcement personnel access to an immersive, real-life, scenario-based training curriculum which will improve community-police relations, as well as officer safety and resilience; S. 2644, the American Law Enforcement Sustaining Aid and Vital Emergency Resources (SAVER) Act, would expand the existing Edward Byrne Memorial Justice Assistance Grant (Byrne-JAG) program to allow for the purchase of trauma kits; S.3522, the Improving Law Enforcement Officer Safety and Wellness Through Data Act, which would require the Attorney General to develop reports relating to violent attacks against law enforcement officers, and for other purposes; S. 3643, the Combating Money Laundering, Terrorist Financing, and Counterfeiting Act, which would update current law concerning hawala and other informal value transfer systems like those used by international terrorists and trafficking organizations, additionally, purposes to double the penalties for those who violate bulk-cash smuggling laws; S. 3763, the Violent Incident Clearance and Technological Investigative Methods (VICTIM) Act, which would establish a grant program administered by the U.S. Department of Justice (DOJ) to help State, Tribal, and local law enforcement agencies improve their clearance rates for homicides and firearm-related violent crimes.

H.R. 595, the Postal Supervisors and Managers Fairness Act, legislation to provide a reasonable timeline for pay consultations between the U.S. Postal Service and the managerial organization representing postal supervisors, managers and postmasters H.R. 595, the Postal Employees Appeal Rights Amendment Act, legislation to provide all Executive Administrative Schedule (EAS) level postal employees the right to appeal adverse actions to the Merit Systems Protection Board H.Con.Res. 277, a House resolution restore postal delivery standards to the level provided in 2012 H.R. 3005/S. 3356, Postal Police Reform Act, legislation to clarify that USPS police offices have law enforcement authority beyond the perimeter of a postal facility H.R. 3721, USPS Shipping Equity Act, legislation to permit the USPS to transport alcoholic beverages in accordance with federal and state laws PI2003-4, Postal Regulatory Commission Docket related to implementation of USPS' 10-year strategic plan ACR2023, Postal Regulatory Commission Annual Compliance Review HR 7629, Protect Our Letter Carrier Act, legislation to require Department of Justice to designate Assistant US Attorneys for postal-related crimes, authorize increase penalties for certain postal-related crimes, and authorize funds to replace postal keys.

Client expense: $26,250 · Firm income: Not reported

H.R. 1322, the "Law Enforcement Officers Equity Act," a bill to amend current law to include certain Federal positions within the definition of law enforcement officer for retirement purposes; entire bill. S. 1658, the "Law Enforcement Officers Parity Act," a bill to amend title 5, United States Code, to include certain Federal positions within the definition of law enforcement officer for retirement purposes; entire bill. S. 3029, the "Honoring Civil Servants Killed in the Line of Duty Act," a bill to amend Title 5, U.S. Code, to increase death gratuities and funeral allowances for federal employees; entire bill. H.R. 5883, the "Honoring Civil Servants Killed in the Line of Duty Act," a bill to amend Title 5, U.S. Code, to increase death gratuities and funeral allowances for federal employees; entire bill. Legislative proposal to allow for a waiver of the annual cap on premium pay for U.S. Marshals Service personnel assigned to judicial protection activities (no bill introduced). Legislative proposal to modify, waive, or eliminate the annual cap on premium pay under 5 USC for federal law enforcement officers (no bill introduced). S. 3427, the "Overtime Pay for Protective Services Act of 2023," a bill to extend the authority to provide employees of the United States Secret Service with overtime pay beyond other statutory limitations; entire bill. Legislative proposal to address the revised policy of the U.S. Office of Personnel Management to take retroactive and prospective assessments from a retiree's retirement annuity supplement in those cases where a Federal Employees Retirement System annuity is divided between the retiree and a former spouse (no bill introduced). Legislative proposal to address the revised policy of the U.S. Office of Personnel Management to take retroactive and prospective assessments from a retiree's retirement annuity supplement in those cases where a Federal Employees Retirement System annuity is divided between the retiree and a former spouse (no bill introduced). Legislative proposal to authorize a Justice Department grant program to enable state and local agencies to hire retired federal law enforcement officers (no bill introduced). H.R. 3005, the "Postal Police Reform Act of 2023," a bill to modify the role and duties of United States Postal Service police officers; entire bill. S. 3356, the "Postal Police Reform Act of 2023," a bill to modify the role and duties of United States Postal Service police officers; entire bill. General education regarding the need to improve efforts to recruit and retain federal law enforcement employees, including addressing the harmful impacts from the statutory caps on overtime pay. General Education concerning harmful impacts of a government shutdown on federal law enforcement, its mission to protect the American people, and its ability to recruit and retain the best talent to serve the nation.

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau (CFPB) Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Sound Principles for Housing Government Sponsored Entity (GSE) Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Legitimate Bank Service Charges and Fees are not Exploitive and Junk Fees CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Realistic Perspective on Financial Inclusion CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks. Postal Banking Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking Public banking (i.e., publicly owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Federal Home Loan Banks in their Comprehensive Review Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. The results of the Comprehensive Review by the FHFA should not disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Rules and Implementation Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve - and must be closed. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. (House and Senate) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) S. 3356 - Postal Police Reform Act of 2023 (Both Sections), legislation that would modify the role and duties of the postal police and inspectors - in our opinion to better combat the theft of mail and help address the issue of bank check fraud (Senate) S. 1838. And H.R. 3881 - Credit Card Competition Act of 2023 (all Sections), legislation that will amend the Electronic Fund Transfer Act to require the Board of Governors of the Federal Reserve System to prescribe regulations relating to network competition in credit card transactions (House and Senate) Letters - Comment Letter to the CFPB regarding Proposed Rule - Required Rulemaking on Personal Financial Data Rights - Docket ID No. CFPB-2023-0052 and RIN 3170-AA78 Joint Trades letter with the Illinois Farm Bureau regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Action Alerts - None Miscellaneous - Reimbursements from the largest banks for fraudulently altered return checks (Fraud Returns) including - the regulators intervention, providing dedicated resources to lodge complaints, Joint Regulatory Supervisory Guidance, dedicated points of contact at the largest banks, Community Bankers Association of Illinois member guidance with directions on filing complaints to the federal regulators, and the enhanced supervision of the largest banks for CDD and CIP compliance (OCC, FDIC, Federal Reserve) Direct Deposit Diversion Fraud and the nexus between this type of fraud and reimbursements for fraudulently altered return checks (Fraud Returns) (Federal Reserve) Joint Trades letter with the Illinois Farm Bureau regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate)

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau (CFPB) Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks. SBA Direct Lending Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Reasonable Rules and Implementation Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished completely and expeditiously. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Harmful Climate Risk Regulations CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. (House and Senate) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) S.J.Res 32 - Joint Resolution nullifying the CFPBs Section 1071 - Small Business Data Collection Rule (House and President) S. 3356 - Postal Police Reform Act of 2023 (Both Sections), legislation that would modify the role and duties of the postal police and inspectors - in our opinion to better combat the theft of mail and help address the issue of bank check fraud (Senate) S. 1838. And H.R. 3881 - Credit Card Competition Act of 2023 (all Sections), legislation that will amend the Electronic Fund Transfer Act to require the Board of Governors of the Federal Reserve System to prescribe regulations relating to network competition in credit card transactions (House and Senate) Letters - Joint Trades letter with the Illinois Farm Bureau regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Action Alerts - None Miscellaneous - Reimbursements from the largest banks for fraudulently altered return checks (Fraud Returns) including - the regulators intervention, providing dedicated resources to lodge complaints, Joint Regulatory Supervisory Guidance, dedicated points of contact at the largest banks, Community Bankers Association of Illinois member guidance with directions on filing complaints to the federal regulators, and the enhanced supervision of the largest banks for CDD and CIP compliance (OCC, FDIC, Federal Reserve) Direct Deposit Diversion Fraud and the nexus between this type of fraud and reimbursements for fraudulently altered return checks (Fraud Returns) (Federal Reserve) Economic Roundtable where bank capital rules were discussed among other topics identified elsewhere in this LDR (House)

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Sound Principles for Housing Government Sponsored Entity (GSE) Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Federal Home Loan Banks in their Comprehensive Review Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. The results of the Comprehensive Review by the FHFA should not disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Rules and Implementation Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished completely and expeditiously. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Harmful Climate Risk Regulations CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. (House and Senate) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) S.J.Res 32 - Joint Resolution nullifying the CFPBs Section 1071 - Small Business Data Collection Rule (House and President) S. 3356 - Postal Police Reform Act of 2023 (Both Sections), legislation that would modify the role and duties of the postal police and inspectors - in our opinion to better combat the theft of mail and help address the issue of bank check fraud (Senate) Letters - Joint Trades letter with the Illinois Farm Bureau regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Action Alerts - None Miscellaneous - Reimbursements from the largest banks for fraudulently altered return checks (Fraud Returns) including - the regulators intervention, providing dedicated resources to lodge complaints, Joint Regulatory Supervisory Guidance, dedicated points of contact at the largest banks, Community Bankers Association of Illinois member guidance with directions on filing complaints to the federal regulators, and the enhanced supervision of the largest banks for CDD and CIP compliance (OCC, FDIC, Federal Reserve) Direct Deposit Diversion Fraud and the nexus between this type of fraud and reimbursements for fraudulently altered return checks (Fraud Returns) (Federal Reserve)

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau (CFPB) Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states, is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for Housing Government Sponsored Entity (GSE) Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Responsible Bank Merger Activity New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Legitimate Bank Service Charges and Fees are not Exploitive and Junk Fees CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Realistic Perspective on Financial Inclusion CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks. SBA Direct Lending Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Postal Banking Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking Public banking (i.e., publicly owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Federal Home Loan Banks in their Comprehensive Review Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. The results of the Comprehensive Review by the FHFA should not disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Rules and Implementation Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished completely and expeditiously. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve - and must be closed. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Appropriate Regulations of Fintechs and Innovation in Financial Services Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Harmful Climate Risk Regulations CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. (House and Senate) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) S.J.Res 32 - Joint Resolution nullifying the CFPBs Section 1071 - Small Business Data Collection Rule (House and President) S. 3356 - Postal Police Reform Act of 2023 (Both Sections), legislation that would modify the role and duties of the postal police and inspectors - in our opinion to better combat the theft of mail and help address the issue of bank check fraud (Senate) S. 1838. And H.R. 3881 - Credit Card Competition Act of 2023 (all Sections), legislation that will amend the Electronic Fund Transfer Act to require the Board of Governors of the Federal Reserve System to prescribe regulations relating to network competition in credit card transactions (House and Senate) Letters - Comment Letter to the CFPB regarding Proposed Rule - Required Rulemaking on Personal Financial Data Rights - Docket ID No. CFPB-2023-0052 and RIN 3170-AA78 Joint Trades letter with the Illinois Farm Bureau regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Action Alerts - None Miscellaneous - Reimbursements from the largest banks for fraudulently altered return checks (Fraud Returns) including - the regulators intervention, providing dedicated resources to lodge complaints, Joint Regulatory Supervisory Guidance, dedicated points of contact at the largest banks, Community Bankers Association of Illinois member guidance with directions on filing complaints to the federal regulators, and the enhanced supervision of the largest banks for CDD and CIP compliance (OCC, FDIC, Federal Reserve) Direct Deposit Diversion Fraud and the nexus between this type of fraud and reimbursements for fraudulently altered return checks (Fraud Returns) (Federal Reserve) Responsible review of the FDIC and deposit insurance limits and finalizing the exemption for community banks from paying a special assessment in connection with the failures of SVB (CA) and SB (NY) (House and Senate)

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau (CFPB) Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states, is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for Housing Government Sponsored Entity (GSE) Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Responsible Bank Merger Activity New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Legitimate Bank Service Charges and Fees are not Exploitive and Junk Fees CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Realistic Perspective on Financial Inclusion CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks. SBA Direct Lending Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Postal Banking Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking Public banking (i.e., publicly owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Federal Home Loan Banks in their Comprehensive Review Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. The results of the Comprehensive Review by the FHFA should not disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Rules and Implementation Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished completely and expeditiously. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve - and must be closed. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Appropriate Regulations of Fintechs and Innovation in Financial Services Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Harmful Climate Risk Regulations CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. (House and Senate) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) S.J.Res 32 - Joint Resolution nullifying the CFPBs Section 1071 - Small Business Data Collection Rule (House and President) S. 3356 - Postal Police Reform Act of 2023 (Both Sections), legislation that would modify the role and duties of the postal police and inspectors - in our opinion to better combat the theft of mail and help address the issue of bank check fraud (Senate) S. 1838. And H.R. 3881 - Credit Card Competition Act of 2023 (all Sections), legislation that will amend the Electronic Fund Transfer Act to require the Board of Governors of the Federal Reserve System to prescribe regulations relating to network competition in credit card transactions (House and Senate) Letters - Comment Letter to the CFPB regarding Proposed Rule - Required Rulemaking on Personal Financial Data Rights - Docket ID No. CFPB-2023-0052 and RIN 3170-AA78 Joint Trades letter with the Illinois Farm Bureau regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Action Alerts - None Miscellaneous - Reimbursements from the largest banks for fraudulently altered return checks (Fraud Returns) including - the regulators intervention, providing dedicated resources to lodge complaints, Joint Regulatory Supervisory Guidance, dedicated points of contact at the largest banks, Community Bankers Association of Illinois member guidance with directions on filing complaints to the federal regulators, and the enhanced supervision of the largest banks for CDD and CIP compliance (OCC, FDIC, Federal Reserve) Direct Deposit Diversion Fraud and the nexus between this type of fraud and reimbursements for fraudulently altered return checks (Fraud Returns) (Federal Reserve) Responsible review of the FDIC and deposit insurance limits and finalizing the exemption for community banks from paying a special assessment in connection with the failures of SVB (CA) and SB (NY) (House and Senate)

H.R. 595, the Postal Supervisors and Managers Fairness Act, legislation to provide a reasonable timeline for pay consultations between the U.S. Postal Service and the managerial organization representing postal supervisors, managers and postmasters H.R. 595, the Postal Employees Appeal Rights Amendment Act, legislation to provide all Executive Administrative Schedule (EAS) level postal employees the right to appeal adverse actions to the Merit Systems Protection Board H.Con.Res. 277, a House resolution restore postal delivery standards to the level provided in 2012 H.R. 3005/S. 3356, Postal Police Reform Act, legislation to clarify that USPS police offices have law enforcement authority beyond the perimeter of a postal facility H.R. 3721, USPS Shipping Equity Act, legislation to permit the USPS to transport alcoholic beverages in accordance with federal and state laws PI2003-4, Postal Regulatory Commission Docket related to implementation of USPS' 10-year strategic plan

Client expense: $25,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), Office of Personnel Management (OPM), Postal Regulatory Commission, SENATE, Treasury, Dept of, U.S. Postal Service (USPS)