Close the Shadow Banking Loophole Act

Issues relating to banking institutions impacting reform. Additional matters related to Community Reinvestment Act (CRA); financial services regulatory reform, U.S. payments systems, anti-money laundering, beneficial ownership; nominations; and bank climate-related stress tests/scenario analysis. S.3600 Strengthening American Cybersecurity Act; S.1838, Credit Card Competition Act of 2023; S.2760, Capping Credit Card Interest Rates Act; H.R. 7531, Secure Payments Act of 2024; S.3538, Close the Shadow Banking Loophole Act; H.R. 9303, Protecting Consumers from Payment Scams Act; S.19, GENIUS Act of 2025, Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025; H.R. 2392, STABLE Act of 2025, Stablecoin Transparency and Accountability for a Better Ledger Economy Act of 2025; S.J. Res. 18, A joint resolution disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Overdraft Lending: Very Large Financial Institutions"; and H.R. 3633, Digital Asset Market Clarity Act of 2025 (CLARITY).

Client expense: $440,000 · Firm income: Not reported

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

Issues relating to banking institutions impacting reform. Matters related to Community Reinvestment Act (CRA), Current Expected Credit Loss (CECL); Matters relating to financial services regulatory reform, U.S. payments systems, anti-money laundering, beneficial ownership; nominations; and bank climate-related stress tests/scenario analysis. H.R. 2471, the Consolidated Appropriations Act 2022; S.3844, Economic Continuity and Stability Act; S. 3600 Strengthening American Cybersecurity Act; and H.R. 5991, the Fair Hiring in Banking Act; S.1838, Credit Card Competition Act of 2023; S.2760, Capping Credit Card Interest Rates Act; S.2190; H.R. 7531, Secure Payments Act of 2024; S.3538, Close the Shadow Banking Loophole Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues relating to banking institutions impacting reform. Matters related to Community Reinvestment Act (CRA), Current Expected Credit Loss (CECL); Paycheck Protection Program. Matters relating to financial services regulatory reform, U.S. payments systems, anti-money laundering, beneficial ownership; nominations; and bank climate-related stress tests/scenario analysis. H.R. 2471, the Consolidated Appropriations Act 2022; S.3844, Economic Continuity and Stability Act; S. 3600 Strengthening American Cybersecurity Act; and H.R. 5991, the Fair Hiring in Banking Act; S.1838, Credit Card Competition Act of 2023; S.2760, Capping Credit Card Interest Rates Act; S.2190, The Recovering Executive Compensation from Unaccountable Practices (RECOUP) Act of 2023. H.R. 7531, Secure Payments Act of 2024; S.3538, Close the Shadow Banking Loophole Act; S.2190, Recovering Executive Compensation Obtained from Unaccountable Practices Act of 2023 (RECOUP Act of 2023).

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to Industrial Loan Companies (ILCs); H.R. 3881/S. 1838 - Credit Card Competition Act of 2023; Issues related to interchange fees; S. 3538 - Close the Shadow Banking Loophole Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues relating to banking institutions impacting reform. Matters related to Community Reinvestment Act (CRA). Matters relating to financial services regulatory reform, U.S. payments systems, anti-money laundering, beneficial ownership; nominations; and bank climate-related stress tests/scenario analysis. S. 3600 Strengthening American Cybersecurity Act; S.1838, Credit Card Competition Act of 2023; S.2760, Capping Credit Card Interest Rates Act; H.R. 7531, Secure Payments Act of 2024; S.3538, Close the Shadow Banking Loophole Act; S.2190, H.R. 9303, Protecting Consumers from Payment Scams Act. S.19, GENIUS Act of 2025, Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025; H.R. 2392, STABLE Act of 2025, Stablecoin Transparency and Accountability for a Better Ledger Economy Act of 2025; and S.J. Res. 18, A joint resolution disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Overdraft Lending: Very Large Financial Institutions".

Client expense: $1,330,000 · Firm income: Not reported

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

H.R. 758 Promoting Access to Capital in Underbanked Communities Act of 2023 H.R. 1806 Small LENDER Act H.R. 1810 Bank Loan Privacy Act H.R. 2656 Trigger Leads Abatement Act H.R. 2891 SAFER Banking Act of 2023 H.R. 3881 Credit Card Competition Act of 2023 H.R. 4766 Clarity for Payment Stablecoins Act of 2023 H.R. 5403 CBDC Anti-Surveillance State Act H.R. 7297 Homebuyers Privacy Protection Act H.R. 9303 Protecting Consumers from Payment Scams Act H.R. 10542 Employee Paycheck and Small Business Protection Act S. 1323 SAFE Banking Act of 2023 S. 1838 Credit Card Competition Act of 2023; Durbin Amendment on Debit Card Routing; Extension to Credit Cards S. 2860 SAFER Banking Act S. 3502 Homeowners Privacy Protection Act (Trigger Leads) S. 3538 Close the Shadow Banking Loophole Act S. 3801 CBDC Anti-Surveillance State Act S. 4155 Lummis -Gillibrand Payment Stablecoin Act S. 4570 Secure Payments Act S. 4638 National Defense Authorization Act for Fiscal Year 2025 S. 4943 Protecting Consumers from Payment Scams Act Senate Amendment 2358 to National Defense Authorization Act (Trigger Leads) Senate Amendment 3290 National Defense Authorization Act (Trigger leads) Anti-money laundering regulation - digital assets Artificial Intelligence Bank Merger Competitive Review Guidelines Bank-fintech partnerships Beneficial Ownership Cannabis Banking Central Bank Digital Currency Check Fraud Community Bank Access to Capital Community Development Financial Institutions Certification Credit Card Routing Mandates Credit Reporting Credit Union Acquisitions of Community Banks Credit Union Business Lending Powers Credit Union Field of Membership Rules Data Privacy De Novo Bank Formation Debit Card Interchange Fees and Routing Deposit Insurance Reform Digital Assets Regulation EGRPRA Review FHFA Capital Rules Flood Insurance Implementation of Dodd Frank Act Section 1071 Implementation issues with the Anti-Money Laundering Act of 2020 Industrial Loan Company Charter Policy Open Banking / Dodd-Frank Section 1033 Opposing the SBAs proposal to repeal the moratorium on the number of Small Business Lending Companies (SBLC) that are permitted to make 7(a) loans. Request for hearing on unfair Credit Union Competition Request that the CFPBs FCRA Rulemaking Process be Subject to an Advanced Notice of Proposed Rulemaking (ANPR) before it Publishes a Notice of Proposed Rulemaking (NPRM) SBA Direct 7(a) Direct Lending

Client expense: $834,820 · Firm income: Not reported

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

Issues relating to banking institutions impacting reform. Matters related to Community Reinvestment Act (CRA). Current Expected Credit Loss (CECL); Paycheck Protection Program. Matters relating to financial services regulatory reform, U.S. payments systems, anti-money laundering, beneficial ownership; nominations; and bank climate-related stress tests/scenario analysis. S. 3600 Strengthening American Cybersecurity Act; S.1838, Credit Card Competition Act of 2023; S.2760, Capping Credit Card Interest Rates Act; H.R. 7531, Secure Payments Act of 2024; S.3538, Close the Shadow Banking Loophole Act; S.2190, Recovering Executive Compensation Obtained from Unaccountable Practices Act of 2023 (RECOUP Act of 2023); and H.R. 9303, Protecting Consumers from Payment Scams Act.

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

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

S. 3538, Close the Shadow Bank Loophole (all provisions).

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

Government targets: HOUSE OF REPRESENTATIVES

S. 3538, Close the Shadow Bank Loophole (all provisions).

Client expense: $220,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES

Digital assets, mobile payments, fraud, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy. FinCEN, Harmonizing CIP products; CFPB proposed rule, Registry of Supervised Nonbanks That Use Form Contracts To Impose Terms and Conditions That Seek To Waive or Limit Consumer Legal Protections; CFPB proposed rule, Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders; White House OSTP RFI, Digital Assets Research and Development. H.R. 1747, "Blockchain Regulatory Certainty Act," H.R. 370, "FinCEN Modernization Act of 2023," H.R. 556, "21st Century Dollar Act," H.R. 8997, "No SmartPay for Anti-2A Companies Act." "H.R. 4192, To apply the Truth in Lending Act to small business financing, and for other purposes," "S. 2021, Small Business Financing Disclosure Act of 2023," "S. 1934, Empowering States' Rights To Protect Consumers Act of 2023," "H.R. 3881, Credit Card Competition Act of 2023," "S. 1838, Credit Card Competition Act of 2023," "S. 1323, SAFE Banking Act of 2023," "H.R. 2891, SAFE Banking Act of 2023." "S. 2281, Lummis-Gillibrand Responsible Financial Innovation Act." "S. 2348,Payments Modernization Act of 2023." "S. 2335, Financial Regulatory Accountability Act of 2023." "S. 2355, Crypto-Asset National Security Enhancement and Enforcement Act of 2023." "H. Res. 604, Expressing support for blockchain technology and digital assets." "H.R. 4766, Clarity for Payment Stablecoins Act of 2023." "H.R. 4763, Financial Innovation and Technology for the 21st Century Act." "S. 2403, Payroll Account Guarantee Act of 2023." "S. 2449, Ensuring Fee-Free Benefit Transactions Act of 2023." "H.R. 4841, Keep Your Coins Act of 2023." "S. 2669, Digital Asset Anti-Money Laundering Act of 2023." "H.R. 5050, Cryptocurrency Accountability Act." "H.R. 5039, Payments Modernization Act of 2023." "H.R. 5032, Cease Orwellian Surveillance and Targeting Act of 2023." "S. 2730, Protecting Consumers from Unreasonable Credit Rates Act of 2023." "S. 2760, Capping Credit Card Interest Rates Act." "H.R. 5403, CBDC Anti-Surveillance State Act." "H.R. 5410, ECASH Act." "H.R. 5447, No Alipay Act of 2023." "H.R. 5472, FinCEN Oversight and Accountability Act of 2023." "H.R. 5485, Financial Privacy Act of 2023." "S. 3538, Close the Shadow Banking Loophole Act." CFPB proposed rule; Section 1033 of Dodd-Frank Act.

Client expense: $410,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Office of Science & Technology Policy (OSTP), SENATE

Issues relating to banking institutions impacting reform. Matters related to Community Reinvestment Act (CRA), Current Expected Credit Loss (CECL); Paycheck Protection Program. Matters relating to financial services regulatory reform, U.S. payments systems, anti-money laundering, beneficial ownership; nominations; and bank climate-related stress tests/scenario analysis. H.R. 2471, the Consolidated Appropriations Act 2022; S.3844, Economic Continuity and Stability Act; S. 3600 Strengthening American Cybersecurity Act; and H.R. 5991, the Fair Hiring in Banking Act; S.1838, Credit Card Competition Act of 2023; S.2760, Capping Credit Card Interest Rates Act; S.2190, The Recovering Executive Compensation from Unaccountable Practices (RECOUP) Act of 2023. H.R. 7531, Secure Payments Act of 2024; S.3538, Close the Shadow Banking Loophole Act; S.2190, Recovering Executive Compensation Obtained from Unaccountable Practices Act of 2023 (RECOUP Act of 2023).

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to Industrial Loan Companies (ILCs); H.R. 3881/S. 1838 - Credit Card Competition Act of 2023; Issues related to interchange fees; S. 3538 - Close the Shadow Banking Loophole Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to Industrial Loan Companies (ILCs); H.R. 3881/S. 1838 - Credit Card Competition Act of 2023; Issues related to interchange fees; S. 3538 - Close the Shadow Banking Loophole Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Legislative activities dealing with implementation and compliance burdens under the Dodd-Frank Wall Street Reform Act & Consumer Protection Act affecting industrial banks, industrial loan companies or Morris Plan Banks. FDIC approval process for insuring de novo banks. Issues affecting brokered deposits. Chartering of de novo banks. S. 3538, Close the Shadow Banking Loophole Act, all provisions.

Client expense: Not reported · Firm income: $34,500

Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), SENATE

Protect the credit union tax exemption Support legislation and regulation that advance credit unions and their over 140 million members Support regulatory relief for credit unions Support credit union field of membership expansion and modernization Support regulator- and bank-approved credit union-bank mergers Support financial inclusion and increased access to financial services Support assistance for minority depository institution credit unions Oppose Community Reinvestment Act requirements for credit unions Support Federal Credit Union Act modernization Support expanded credit union investment authority Support expanded credit union examination cycle Support increased examination transparency Support Central Liquidity Facility enhancements Oppose NCUA examination of credit union vendors Support parity for credit union provision of digital asset services Prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products Support parity for credit unions related to stablecoin regulation Support modification of credit union loan maturity limits Oppose National Credit Union Share Insurance Fund structural changes Oppose National Credit Union Share Insurance Fund premium assessment Support parity in deposit insurance coverage levels between credit unions and banks Issues related to housing finance reform Issues related to flood insurance Issues related to privately insured credit unions Issues related to credit union capital requirements Issues related to credit union conversions Issues related to credit unions as employers Issues related to the Foreign Account Tax Compliance Act Issues related to fair lending Issues related to the Telephone Consumer Protection Act Support mandatory arbitration agreements Oppose national interest rate cap Support reduced government-sponsored enterprises costs for credit union mortgages Support secondary mortgage market access for credit unions Support credit union access to Federal Home Loan Banks system Support making CFPB subject to regular appropriations process Support restructuring CFPB leadership to a bipartisan commission Support increasing asset thresholds for CFPB supervision Support clarification of CFPB unfair, deceptive, or abusive acts and practices authority Support CFPB use of Section 1022 authority to exempt credit unions from certain regulations Support CFPB oversight and monitoring of nonbank entities Oppose CFPB efforts to avoid requirements of the rulemaking process Support CFPB use and disclosure of relevant data in rulemakings Support CFPB policies to promote innovation and access to credit Support CFPB coordination with NCUA on policy matters and examination scheduling Oppose mislabeling financial services fees as junk fees Oppose arbitrary limits on credit union fee income Support federal data privacy and security standard that exempts Gramm-Leach-Bliley Act covered institutions, preempts state laws, and does not authorize private right of action Oppose Regulation II debit interchange fee cap Oppose Federal Reserve proposed rule on modifying Regulation II debit interchange cap Support holistic evaluation of regulatory burden on credit unions Oppose expansion of Electronic Fund Transfer Act/Regulation E financial institution liability Support fair distribution of Electronic Fund Transfer Act/Regulation E error resolution responsibilities Oppose Electronic Fund Transfer Act/Regulation E liability for financial institutions for consumer-authorized transactions Oppose nominal leases for banks on military installations Oppose development of a central bank digital currency Oppose proposed new tax reporting requirements for financial institutions Support credit union access to Federal Reserve liquidity options Support FinCEN implementation of the Corporate Transparency Act Support exemptions for CFPB Section 1071 final rule Oppose legislative action on the Overseas Military Banking Program Oppose credit union-related amendments to the FY 2025 National Defense Authorization Act Support federal share insurance for all credit unions acting as fiscal agents of the U.S. government Oppose CFPB proposed rule on overdraft for very large financial institutions Oppose CFPB proposed rule on NSF fees Oppose CFPB efforts to restrict information in credit reports Oppose Credit Card Competition Act (H.R. 3881, S. 1838) Support Secure and Fair Enforcement Banking Act (H.R. 2891; S. 1323) Support Secure And Fair Enforcement Regulation Banking Act (S. 2860) Oppose Capping Credit Card Interest Rates Act (S. 2760) Support Close the Shadow Banking Loophole Act (S. 3538) Support Business of Insurance Regulatory Reform Act (H.R. 7000; S. 3592) Oppose Strengthening Cybersecurity for the Financial Sector Act (H.R. 7036) Support resolution of disapproval for CFPB credit card penalty fees final rule (S.J.Res. 70; H.J.Res. 122) Support CBDC Anti-Surveillance State Act (H.R. 5403; S. 3801) Support CDFI Fund Transparency Act (S. 3161; S. 2674) Support Consumer Financial Protection Commission Act (H.R. 1410) Support CFPB Transparency and Accountability Reform Act (H.R. 2798) Support Fair Audits and Inspections for Regulators Exams Act (H.R. 8071) Support Credit Union Board Modernization Act (H.R. 582, S. 610) Support Member Business Loan Expansion Act (H.R. 4868) Support Veterans Member Business Loan Act (H.R. 4867; S. 539) Support Expanding Access to Lending Options Act (H.R. 6933) Oppose House NDAA Amendment #645 on the Overseas Military Banking Program Support Rural Credit Access Act (H.R. 7338) Support Secure Payments Act (H.R. 7531; S. 4570) Support Consumer Financial Protection Bureau Accountability Act (S. 4521) Oppose American Privacy Rights Act (H.R. 8818) Oppose inclusion of American Privacy Rights Act as amendment to other legislation Oppose Protecting Consumers from Payment Scams Act (H.R. 9303; S. 4943) Support Affordable Future Loan Program Act (S. 4926) Support balanced regulatory framework in AI Act of 2024 (H.R. 10262) Oppose requirement for filing a single joint report in AI Act of 2024 (H.R. 10262) Support Central Liquidity Facility Enhancement Act (H.R. 10510) Support field of membership expansion in Expanding Financial Access for Underserved Communities Act (H.R. 10511) Oppose NDAA amendments on interchange and military banking Support passage of a clean NDAA Oppose CFPB credit card penalty fees final rule Oppose CFPB Section 1071 final rule Oppose CFPB Section 1033 final rule Oppose NCUA Call Report collection of overdraft and NSF fee revenue data Oppose NCUA disclosure of credit union overdraft and NSF fee revenue data Support NCUA action to permit credit union reimbursement of childcare expenses for federal credit union board meetings Oppose collection of vendor information in NCUA Credit Union Profile Oppose changes to NCUA collection forms outside rulemaking process Oppose NCUA proposed rule on succession planning Oppose CFPB mischaracterization of overdraft programs Oppose CFPB proposed rule on modifications to mortgage loss mitigation regulations Support gradual expansion of Fedwire and National Settlement Service operating hours with optional participation Support NCUA recognition of digital banking in service facility definition Support clarification of NCUA member expulsion regulations Support NCUA proposed rule on increasing overdraft flexibility Support NCUA recognition of government sponsored enterprises as government agencies for loan maturity limit purposes Support NCUA adoption of floating interest rate cap Support modification of NCUA commercial loan definition Support increased flexibility in NCUA occupancy requirements Support NCUA modification of low-income designation process Support expanding NCUA qualified charity definition Support expansion of Federal Home Loan Bank Act community financial institution definition Support Federal Home Loan Bank engagement with credit unions Oppose adoption of volume-based incentives for Federal Home Loan Banks Oppose policy changes to limit access to Federal Home Loan Bank liquidity Support harmonization of federal cyber incident notification standards Oppose CFPB action to shift burden of negotiating mortgage closing fees to financial institutions Support credit union access to universal service fund letters of credit program Support additional time to implement anti-money laundering/countering financing of terrorism program changes and publication of guidance Support consistency between NCUA and FinCEN requirements on Bank Secrecy Act compliance Support consumer protection regulations for buy-now-pay-later loan providers Support regulatory framework for artificial intelligence that allows responsible innovation and recognizes compliance with existing regulations Oppose prohibition on use of medical debt information in credit decisions Oppose addition of fourth same-day ACH window Support expanded flexibility for accessing the Fed discount window and intraday credit Oppose CFPB rulemaking activity before transition in administrations Oppose additional Call Report fields on loans to credit union officials and senior executive staff Oppose making changes to Call Report requirements without using notice-and-comment process Support enhanced clarity in proposed amendments to remittance rule Oppose CFPB efforts to manipulate consumer complaint data Oppose proposed incentive-based compensation rule Support recognition of unique credit union structure in Financial Data Transparency Act joint data standards

Client expense: $1,440,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Natl Credit Union Administration (NCUA), Office of Management & Budget (OMB), SENATE, Small Business Administration (SBA), Treasury, Dept of

legislation regarding the CFPB and regulation of the consumer credit industry, credit reporting legislation, auto lending regulations, TABS Act, CFPB Commission, data privacy in banking, and prevention of any legislation imposing rate caps, maintaining the status of industrial banks (oppose S. 3538, letter to FDIC protecting ILCs), CFPB examination of abusive practices and nonbank practices, CFPB as relating to the auto industry and data collection

Client expense: $280,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, SENATE, White House Office

H.R. 758 Promoting Access to Capital in Underbanked Communities Act of 2023 H.R. 1806 Small LENDER Act H.R. 1810 Bank Loan Privacy Act H.R. 2656 Trigger Leads Abatement Act H.R. 2891 SAFER Banking Act of 2023 H.R. 3161 CDFI Fund Transparency Act H.R. 3881 Credit Card Competition Act of 2023 H.R. 4766 Clarity for Payment Stablecoins Act of 2023 H.R. 5403 CBDC Anti-Surveillance State Act H.R. 6789 Rectifying Undefined Descriptions of Abusive Act and Practices Act H.R. 7297 Homebuyers Privacy Protection Act H.R. 7420 Ensuring Diversity in Community Banking Act H.R. 7483 Expanding Opportunity for MDIs Act H.R. 7531 Secure Payments Act HR 7890 Amendment in the Nature of a Substitute - American Privacy Rights Act H.R. 8818 American Privacy Rights Act HR 9303 Protecting Consumers from Payment Scams Act S. 1323 SAFE Banking Act of 2023 S. 1838 Credit Card Competition Act of 2023; Durbin Amendment on Debit Card Routing; Extension to Credit Cards S. 2860 SAFER Banking Act S. 3502 Homeowners Privacy Protection Act (Trigger Leads) S. 3538 Close the Shadow Banking Loophole Act S. 3801 CBDC Anti-Surveillance State Act S. 4155 Lummis -Gillibrand Payment Stablecoin Act S. 4570 Secure Payments Act S. 4638 National Defense Authorization Act for Fiscal Year 2025 S. 4943 Protecting Consumers from Payment Scams Act Senate Amendment 2358 to National Defense Authorization Act (Trigger Leads) Senate Amendment 3290 National Defense Authorization Act (Trigger leads) Anti-money laundering regulation - digital assets Artificial Intelligence Bank Merger Competitive Review Guidelines Bank-fintech partnerships Beneficial Ownership Cannabis Banking Central Bank Digital Currency Check Fraud Community Bank Access to Capital Community Development Financial Institutions Certification Community Reinvestment Act Credit Card Routing Mandates Credit Reporting Credit Union Acquisitions of Community Banks Credit Union Business Lending Powers Credit Union Field of Membership Rules Data Privacy De Novo Bank Formation Debit Card Interchange Fees and Routing Digital Assets Regulation EGRPRA Review FHFA Capital Rules Flood Insurance Implementation of Dodd Frank Act Section 1071 Implementation issues with the Anti-Money Laundering Act of 2020 Industrial Loan Company Charter Policy Instant Payments NSF and Overdraft Fees Open Banking / Dodd-Frank Section 1033 Opposing the SBAs proposal to repeal the moratorium on the number of Small Business Lending Companies (SBLC) that are permitted to make 7(a) loans. Payments Fraud Request for hearing on unfair Credit Union Competition Request that the CFPBs FCRA Rulemaking Process be Subject to an Advanced Notice of Proposed Rulemaking (ANPR) before it Publishes a Notice of Proposed Rulemaking (NPRM) SBA Direct 7(a) Direct Lending

Client expense: $736,305 · Firm income: Not reported

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

Digital assets, mobile payments, fraud, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy. FinCEN, Harmonizing CIP products; CFPB proposed rule, Registry of Supervised Nonbanks That Use Form Contracts To Impose Terms and Conditions That Seek To Waive or Limit Consumer Legal Protections; CFPB proposed rule, Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders; White House OSTP RFI, Digital Assets Research and Development. H.R. 1747, "Blockchain Regulatory Certainty Act," H.R. 370, "FinCEN Modernization Act of 2023," H.R. 556, "21st Century Dollar Act," H.R. 8997, "No SmartPay for Anti-2A Companies Act." "H.R. 4192, To apply the Truth in Lending Act to small business financing, and for other purposes," "S. 2021, Small Business Financing Disclosure Act of 2023," "S. 1934, Empowering States' Rights To Protect Consumers Act of 2023," "H.R. 3881, Credit Card Competition Act of 2023," "S. 1838, Credit Card Competition Act of 2023," "S. 1323, SAFE Banking Act of 2023," "H.R. 2891, SAFE Banking Act of 2023." "S. 2281, Lummis-Gillibrand Responsible Financial Innovation Act." "S. 2348,Payments Modernization Act of 2023." "S. 2335, Financial Regulatory Accountability Act of 2023." "S. 2355, Crypto-Asset National Security Enhancement and Enforcement Act of 2023." "H. Res. 604, Expressing support for blockchain technology and digital assets." "H.R. 4766, Clarity for Payment Stablecoins Act of 2023." "H.R. 4763, Financial Innovation and Technology for the 21st Century Act." "S. 2403, Payroll Account Guarantee Act of 2023." "S. 2449, Ensuring Fee-Free Benefit Transactions Act of 2023." "H.R. 4841, Keep Your Coins Act of 2023." "S. 2669, Digital Asset Anti-Money Laundering Act of 2023." "H.R. 5050, Cryptocurrency Accountability Act." "H.R. 5039, Payments Modernization Act of 2023." "H.R. 5032, Cease Orwellian Surveillance and Targeting Act of 2023." "S. 2730, Protecting Consumers from Unreasonable Credit Rates Act of 2023." "S. 2760, Capping Credit Card Interest Rates Act." "H.R. 5403, CBDC Anti-Surveillance State Act." "H.R. 5410, ECASH Act." "H.R. 5447, No Alipay Act of 2023." "H.R. 5472, FinCEN Oversight and Accountability Act of 2023." "H.R. 5485, Financial Privacy Act of 2023." "S. 3538, Close the Shadow Banking Loophole Act." CFPB proposed rule; Section 1033 of Dodd-Frank Act.

Client expense: $410,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Office of Science & Technology Policy (OSTP), SENATE

Issues relating to banking institutions impacting reform. Matters related to Community Reinvestment Act (CRA), Current Expected Credit Loss(CECL); Paycheck Protection Program. Matters relating to financial services regulatory reform, U.S. payments systems, anti-money laundering, beneficial ownership; nominations; and bank climate-related stress tests/scenario analysis. H.R. 2471, the Consolidated Appropriations Act 2022; S.3844, Economic Continuity and Stability Act; S. 3600 Strengthening American Cybersecurity Act; and H.R. 5991, the Fair Hiring in Banking Act; S.1838, Credit Card Competition Act of 2023; S.2760, Capping Credit Card Interest Rates Act; S.2190, The Recovering Executive Compensation from Unaccountable Practices (RECOUP) Act of 2023. H.R. 7531, Secure Payments Act of 2024; S.3538, Close the Shadow Banking Loophole Act; S.2190, Recovering Executive Compensation Obtained from Unaccountable Practices Act of 2023 (RECOUP Act of 2023).

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Protect the credit union tax exemption Support legislation and regulation that advance credit unions and their over 140 million members Support regulatory relief for credit unions Support credit union field of membership expansion and modernization Support regulator- and bank-approved credit union-bank mergers Support financial inclusion and increased access to financial services Support assistance for minority depository institution credit unions Oppose Community Reinvestment Act requirements for credit unions Support Federal Credit Union Act modernization Support expanded credit union investment authority Support expanded credit union examination cycle Support increased examination transparency Support Central Liquidity Facility enhancements Oppose NCUA examination of credit union vendors Support parity for credit union provision of digital asset services Prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products Support parity for credit unions related to stablecoin regulation Support modification of credit union loan maturity limits Oppose National Credit Union Share Insurance Fund structural changes Oppose National Credit Union Share Insurance Fund premium assessment Support Community Development Financial Institutions Fund transparency Issues related to housing finance reform Issues related to flood insurance Issues related to privately insured credit unions Issues related to credit union capital requirements Issues related to credit union conversions Issues related to credit unions as employers Issues related to the Foreign Account Tax Compliance Act Issues related to fair lending Issues related to the Telephone Consumer Protection Act Support mandatory arbitration agreements Oppose national interest rate cap Support reduced government-sponsored enterprises costs for credit union mortgages Support secondary mortgage market access for credit unions Support credit union access to Federal Home Loan Banks system Support making CFPB subject to regular appropriations process Support restructuring CFPB leadership to a bipartisan commission Support increasing asset thresholds for CFPB supervision Support clarification of CFPB unfair, deceptive, or abusive acts and practices authority Support CFPB use of Section 1022 authority to exempt credit unions from certain regulations Support CFPB oversight and monitoring of nonbank entities Oppose CFPB efforts to avoid requirements of the rulemaking process Support CFPB use and disclosure of relevant data in rulemakings Support CFPB policies to promote innovation and access to credit Support CFPB coordination with NCUA on policy matters and examination scheduling Oppose mislabeling financial services fees as junk fees Oppose arbitrary limits on credit union fee income Support federal data privacy and security standard that exempts Gramm-Leach-Bliley Act covered institutions, preempts state laws, and does not authorize private right of action Oppose Regulation II debit interchange fee cap Oppose Federal Reserve proposed rule on modifying Regulation II debit interchange cap Support holistic evaluation of regulatory burden on credit unions Oppose expansion of Electronic Fund Transfer Act/Regulation E financial institution liability Support fair distribution of Electronic Fund Transfer Act/Regulation E error resolution responsibilities Oppose Electronic Fund Transfer Act/Regulation E liability for financial institutions for consumer-authorized transactions Oppose nominal leases for banks on military installations Oppose development of a central bank digital currency Oppose proposed new tax reporting requirements for financial institutions Support credit union access to Federal Reserve liquidity options Support FinCEN implementation of the Corporate Transparency Act Support exemptions for CFPB Section 1071 final rule Oppose legislative action on the Overseas Military Banking Program Oppose credit union-related amendments to the FY 2025 National Defense Authorization Act Support federal share insurance for all credit unions acting as fiscal agents of the U.S. government Oppose CFPB proposed rule on overdraft for very large financial institutions Oppose CFPB efforts to restrict information in credit reports Oppose Credit Card Competition Act (H.R. 3881, S. 1838) Support Secure and Fair Enforcement Banking Act (H.R. 2891; S. 1323) Support Secure And Fair Enforcement Regulation Banking Act (S. 2860) Oppose Capping Credit Card Interest Rates Act (S. 2760) Support Close the Shadow Banking Loophole Act (S. 3538) Support Business of Insurance Regulatory Reform Act (H.R. 7000; S. 3592) Oppose Strengthening Cybersecurity for the Financial Sector Act (H.R. 7036) Support resolution of disapproval for CFPB credit card penalty fees final rule (S.J.Res. 70; H.J.Res. 122) Support CBDC Anti-Surveillance State Act (H.R. 5403; S. 3801) Support CDFI Fund Transparency Act (S. 3161; S. 2674) Support Consumer Financial Protection Commission Act (H.R. 1410) Support CFPB Transparency and Accountability Reform Act (H.R. 2798) Support Fair Audits and Inspections for Regulators Exams Act (H.R. 8071) Support Credit Union Board Modernization Act (H.R. 582, S. 610) Support Member Business Loan Expansion Act (H.R. 4868) Support Veterans Member Business Loan Act (H.R. 4867; S. 539) Support Expanding Access to Lending Options Act (H.R. 6933) Oppose House National Defense Authorization Act Amendment #645 on the Overseas Military Banking Program Support Rural Credit Access Act (H.R. 7338) Support Secure Payments Act (H.R. 7531; S. 4570) Support Consumer Financial Protection Bureau Accountability Act (S. 4521) Oppose American Privacy Rights Act (H.R. 8818) Oppose inclusion of American Privacy Rights Act as amendment to other legislation Oppose Protecting Consumers from Payment Scams Act (H.R. 9303; S. 4943) Support Affordable Future Loan Program Act (S. 4926) Oppose CFPB credit card penalty fees final rule Oppose CFPB Section 1071 final rule Oppose CFPB Section 1033 proposed rule Oppose NCUA Call Report collection of overdraft and NSF fee revenue data Oppose NCUA disclosure of credit union overdraft and NSF fee revenue data Support NCUA action to permit credit union reimbursement of childcare expenses for federal credit union board meetings Oppose collection of vendor information in NCUA Credit Union Profile Oppose changes to NCUA collection forms outside rulemaking process Oppose NCUA proposed rule on succession planning Oppose CFPB mischaracterization of overdraft programs Oppose CFPB proposed rule on modifications to mortgage loss mitigation regulations Support gradual expansion of Fedwire and National Settlement Service operating hours with optional participation Support NCUA recognition of digital banking in service facility definition Support clarification of NCUA member expulsion regulations Support NCUA proposed rule on increasing overdraft flexibility Support NCUA recognition of government sponsored enterprises as government agencies for loan maturity limit purposes Support NCUA adoption of floating interest rate cap Support modification of NCUA commercial loan definition Support increased flexibility in NCUA occupancy requirements Support NCUA modification of low-income designation process Support expanding NCUA qualified charity definition Support expansion of Federal Home Loan Bank Act community financial institution definition Support Federal Home Loan Bank engagement with credit unions Oppose adoption of volume-based incentives for Federal Home Loan Banks Oppose policy changes to limit access to Federal Home Loan Bank liquidity Support harmonization of federal cyber incident notification standards Oppose CFPB action to shift burden of negotiating mortgage closing fees to financial institutions Support credit union access to universal service fund letters of credit program Support additional time to implement anti-money laundering/countering financing of terrorism program changes and publication of guidance Support consumer protection regulations for buy-now-pay-later loan providers Support regulatory framework for artificial intelligence that allows responsible innovation and recognizes compliance with existing regulations Oppose prohibition on use of medical debt information in credit decisions

Client expense: $1,090,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Natl Credit Union Administration (NCUA), Office of Management & Budget (OMB), SENATE, Small Business Administration (SBA), Treasury, Dept of

Issues related to Industrial Loan Companies (ILCs); S. 1838/H.R. 3881 - Credit Card Competition Act of 2023, issues related to interchange fees: S. 3538 - Close the Shadow Banking Loophole Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to Industrial Loan Companies (ILCs); S. 1838/H.R. 3881 - Credit Card Competition Act of 2023, issues related to interchange fees: S. 3538 - Close the Shadow Banking Loophole Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related Industrial Loan Company (ILC) charters; S. 3538 - Close the Shadow Banking Loophole Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related Industrial Loan Company (ILC) charters; S. 3538 - Close the Shadow Banking Loophole Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 3538, Close the Shadow Bank Loophole (all provisions).

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

Government targets: HOUSE OF REPRESENTATIVES

Legislative activities dealing with implementation and compliance burdens under the Dodd-Frank Wall Street Reform Act & Consumer Protection Act affecting industrial banks, industrial loan companies or Morris Plan Banks. FDIC approval process for insuring de novo banks. Issues affecting brokered deposits. Chartering of de novo banks. S. 3538, Close the Shadow Banking Loophole Act, all provisions.

Client expense: Not reported · Firm income: $34,500

Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), SENATE

Issues relating to banking institutions impacting reform. Matters related to Community Reinvestment Act (CRA). Current Expected Credit Loss (CECL); Paycheck Protection Program. Matters relating to financial services regulatory reform, U.S. payments systems, anti-money laundering, beneficial ownership; nominations; and bank climate-related stress tests/scenario analysis. S. 3600 Strengthening American Cybersecurity Act; S.1838, Credit Card Competition Act of 2023; S.2760, Capping Credit Card Interest Rates Act; H.R. 7531, Secure Payments Act of 2024; S.3538, Close the Shadow Banking Loophole Act; S.2190, Recovering Executive Compensation Obtained from Unaccountable Practices Act of 2023 (RECOUP Act of 2023); and H.R. 9303, Protecting Consumers from Payment Scams Act.

Client expense: $360,000 · Firm income: Not reported

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

legislation regarding the CFPB and regulation of the consumer credit industry, credit reporting legislation, auto lending regulations, TABS Act, CFPB Commission, data privacy in banking, and prevention of any legislation imposing rate caps, maintaining the status of industrial banks (oppose S. 3538, letter to FDIC protecting ILCs), CFPB examination of abusive practices and nonbank practices, CFPB as relating to the auto industry and data collection

Client expense: $280,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, SENATE, White House Office

S. 3538, Close the Shadow Bank Loophole (all provisions).

Client expense: $230,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES

Credit Union Loan Maturity Issues Credit Union Field of Membership issues S. 539 - Veterans Member Business Loan Act H.R. 4867 - Veterans Member Business Loan Act Issues related to housing Finance Reform Financial Services Regulatory Relief issues Issues related to consumer financial protection Issues related to Digital Assets Credit Union Tax Status Issues related to National Credit Union Administration Examination Procedures Proposed new tax reporting requirements for financial institutions Foreign Account Tax Compliance Act Issues related Credit Card Late Fee Rule H.R. 4868, the Member Business Loan Expansion Act S. 3992, Protecting Access to Credit for Small Businesses Act H.R. 6933, the Expanding Access to Lending Options Act H.R. 3161, the CDFI Fund Transparency Act H.R. 7338, the Rural Credit Access Act of 2024 Issues related to changes to NCUA call report re overdraft/non-sufficient funds fee disclosures Issues related to Overseas Military Banking Program Issues related to Greenhouse Gas Reduction Fund Issues related to CFPB Junk Fees Regulations Issues related to Federal Home Loan Banks Issues related to Overdraft and Non-sufficient Funds Fees Issues related to Fair Lending Issues related to credit union conversions Issues related to Financial inclusion H.J.Res. 122 - Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to "Credit Card Penalty Fees (Regulation Z) H.R. 7036 Strengthening Cybersecurity for the Financial Sector Act H.R. 7000; S. 3592 Business of Insurance Regulatory Reform Act EPA Greenhouse Gas Reduction Fund Issues related to flood insurance Support regulator- and bank-approved credit union-bank mergers Support assistance for MDI credit unions Oppose CRA requirements for credit unions Support FCU Act modernization Support expanded credit union investment authority Support expanded credit union examination cycle Support increased examination transparency Support Central Liquidity Facility enhancements Support parity for credit unions related to stablecoin regulation Support mandatory arbitration agreements Oppose national interest rate cap Support reduced GSE costs for credit union mortgages Support secondary mortgage market access for credit unions Support making CFPB subject to regular appropriations process Support restructuring CFPB leadership to a bipartisan commission Support increasing asset thresholds for CFPB supervision Support clarification of CFPB UDAAP authority Support CFPB use of Section 1022 authority to exempt credit unions from certain regulations Support CFPB oversight and monitoring of nonbank entities Oppose CFPB efforts to avoid requirements of the rulemaking process Support CFPB use and disclosure of relevant data in rulemakings Support CFPB policies to promote innovation and access to credit Support CFPB coordination with NCUA on policy matters and examination scheduling Oppose arbitrary limits on credit union fee income Support holistic evaluation of regulatory burden on credit unions Oppose expansion of Regulation E financial institution liability; Support fair distribution of Regulation E error resolution responsibilities Oppose Regulation E liability for financial institutions for consumer-authorized transactions Oppose nominal leases for banks on military installations Oppose development of a CBDC Support credit union access to Federal Reserve liquidity options Oppose proposed CFPB auto lending data collection Support FinCEN implementation of the Corporate Transparency Act Support exemptions for CFPB Section 1071 final rule Oppose legislative action on the Overseas Military Banking Program Oppose credit union-related amendments to the FY 2025 NDAA Support federal share insurance for all credit unions acting as fiscal agents of the U.S. government Oppose CFPB proposed rule on overdraft for very large financial institutions Oppose CFPB efforts to restrict information in credit reports Oppose Credit Card Competition Act (H.R. 3881, S. 1838) Support SAFE Banking Act (H.R. 2891; S. 1323) Support SAFER Banking Act (S. 2860) Oppose Capping Credit Card Interest Rates Act (S. 2760) Support Close the Shadow Banking Loophole Act (S. 3538) Support CBDC Anti-Surveillance State Act (H.R. 5403; S. 3801) Support Consumer Financial Protection Commission Act (H.R. 1410) Support CFPB Transparency and Accountability Reform Act (H.R. 2798) Support FAIR Exams Act (H.R. 8071) Support Credit Union Board Modernization Act (H.R. 582, S. 610) Support Secure Payments Act (H.R. 7531; S. 4570) Support Consumer Financial Protection Bureau Accountability Act (S. 4521) Oppose American Privacy Rights Act (H.R. 8818) Oppose CFPB Section 1071 final rule Oppose CFPB Section 1033 proposed rule Support NCUA action to permit credit union reimbursement of childcare expenses for FCU board meetings Support modification of FHFA first-generation homebuyer definition

Client expense: $1,460,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Environmental Protection Agency (EPA), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), SENATE, Small Business Administration (SBA), Treasury, Dept of

Digital assets, mobile payments, fraud, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy. FinCEN, Harmonizing CIP products; CFPB proposed rule, Registry of Supervised Nonbanks That Use Form Contracts To Impose Terms and Conditions That Seek To Waive or Limit Consumer Legal Protections; CFPB proposed rule, Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders; White House OSTP RFI, Digital Assets Research and Development. H.R. 1747, "Blockchain Regulatory Certainty Act," H.R. 370, "FinCEN Modernization Act of 2023," H.R. 556, "21st Century Dollar Act," H.R. 8997, "No SmartPay for Anti-2A Companies Act." "H.R. 4192, To apply the Truth in Lending Act to small business financing, and for other purposes," "S. 2021, Small Business Financing Disclosure Act of 2023," "S. 1934, Empowering States' Rights To Protect Consumers Act of 2023," "H.R. 3881, Credit Card Competition Act of 2023," "S. 1838, Credit Card Competition Act of 2023," "S. 1323, SAFE Banking Act of 2023," "H.R. 2891, SAFE Banking Act of 2023." "S. 2281, Lummis-Gillibrand Responsible Financial Innovation Act." "S. 2348,Payments Modernization Act of 2023." "S. 2335, Financial Regulatory Accountability Act of 2023." "S. 2355, Crypto-Asset National Security Enhancement and Enforcement Act of 2023." "H. Res. 604, Expressing support for blockchain technology and digital assets." "H.R. 4766, Clarity for Payment Stablecoins Act of 2023." "H.R. 4763, Financial Innovation and Technology for the 21st Century Act." "S. 2403, Payroll Account Guarantee Act of 2023." "S. 2449, Ensuring Fee-Free Benefit Transactions Act of 2023." "H.R. 4841, Keep Your Coins Act of 2023." "S. 2669, Digital Asset Anti-Money Laundering Act of 2023." "H.R. 5050, Cryptocurrency Accountability Act." "H.R. 5039, Payments Modernization Act of 2023." "H.R. 5032, Cease Orwellian Surveillance and Targeting Act of 2023." "S. 2730, Protecting Consumers from Unreasonable Credit Rates Act of 2023." "S. 2760, Capping Credit Card Interest Rates Act." "H.R. 5403, CBDC Anti-Surveillance State Act." "H.R. 5410, ECASH Act." "H.R. 5447, No Alipay Act of 2023." "H.R. 5472, FinCEN Oversight and Accountability Act of 2023." "H.R. 5485, Financial Privacy Act of 2023." "S. 3538, Close the Shadow Banking Loophole Act." CFPB proposed rule; Section 1033 of Dodd-Frank Act.

Client expense: $410,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Office of Science & Technology Policy (OSTP), SENATE

Issues relating to banking institutions impacting reform. Matters related to Community Reinvestment Act (CRA), Current Expected Credit Loss (CECL); Paycheck Protection Program. Matters relating to financial services regulatory reform, U.S. payments systems, anti-money laundering, beneficial ownership; nominations; and bank climate-related stress tests/scenario analysis. H.R. 2471, the Consolidated Appropriations Act 2022; S. 3844, Economic Continuity and Stability Act; S. 3600 Strengthening American Cybersecurity Act; and H.R. 5991, the Fair Hiring in Banking Act; S.1838, Credit Card Competition Act of 2023; S.2760, Capping Credit Card Interest Rates Act; S.2190, The Recovering Executive Compensation from Unaccountable Practices (RECOUP) Act of 2023. H.R. 7531, Secure Payments Act of 2024; S.3538, Close the Shadow Banking Loophole Act; S.2190, Recovering Executive Compensation Obtained from Unaccountable Practices Act of 2023 (RECOUP Act of 2023).

Client expense: $470,000 · Firm income: Not reported

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

Legislative activities dealing with implementation and compliance burdens under the Dodd-Frank Wall Street Reform Act & Consumer Protection Act affecting industrial banks, industrial loan companies or Morris Plan Banks. FDIC approval process for insuring de novo banks. Issues affecting brokered deposits. Chartering of de novo banks. S. 3538, Close the Shadow Banking Loophole Act, all provisions.

Client expense: Not reported · Firm income: $11,500

Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), SENATE

Issues related to Industrial Loan Companies (ILCs); S. 1838/H.R. 3881 - Credit Card Competition Act of 2023; Issues related to interchange fees; S. 3538 - Close the Shadow Banking Loophole Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to Industrial Loan Companies (ILCs); S. 1838/H.R. 3881 - Credit Card Competition Act of 2023; Issues related to interchange fees; S. 3538 - Close the Shadow Banking Loophole Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to Industrial Loan Company (ILC) charters; S. 3538 - Close the Shadow Banking Loophole Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to Industrial Loan Company (ILC) charters; S. 3538 - Close the Shadow Banking Loophole Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

legislation regarding the CFPB and regulation of the consumer credit industry, credit reporting legislation, auto lending regulations, TABS Act, CFPB Commission, data privacy in banking, and prevention of any legislation imposing rate caps, maintaining the status of industrial banks (oppose S. 3538), CFPB examination of abusive practices and nonbank practices, CFPB as relating to the auto industry and data collection

Client expense: $280,000 · Firm income: Not reported

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

Legislative activities dealing with implementation and compliance burdens under the Dodd-Frank Wall Street Reform Act & Consumer Protection Act affecting industrial banks, industrial loan companies or Morris Plan Banks. FDIC approval process for insuring de novo banks. Issues affecting brokered deposits. Chartering of de novo banks. S. 3538, Close the Shadow Banking Loophole Act, all provisions.

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

Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), SENATE

Credit Card Interchange Fees - S. 1838 and H.R. 3881 - Credit Card Competition Act of 2023 Credit Union Loan Maturity Issues Issues related to access to financial services Credit Union Field of Membership issues Issues related to Credit Union Member Business Lending Caps S. 539 - Veterans Member Business Loan Act H.R. 4867 - Veterans Member Business Loan Act Issues related to housing Finance Reform Financial Services Regulatory Relief issues Issues related to Data Security and Data Privacy S. 610 - Credit Union Board Modernization Act S.2860 - Secure and Fair Enforcement Regulation Banking Act S. 1323 - Secure and Fair Enforcement Banking Act S. 2760 - Capping Credit Card Interest Rates Act S. 3538, Close the Shadow Banking Loophole Act Issues related to the National Defense Authorization Act Issues related to the Consumer Financial Protection Board Issues related to consumer financial protection Issues related to Community Development Financial Institutions Issues related to the Community Development Revolving Loan Fund Issues related to Credit Union Loan Maturities Issues related to Digital Assets Credit Union Tax Status Issues related to Financial Services Regulatory Relief Issues related to National Credit Union Administration Examination Procedures Proposed new tax reporting requirements for financial institutions Postal Banking Issues related to FinCEN and appropriations thereto Issues related to privately insured credit unions Issues related to the Federal Reserves new liquidity facility Issues related to the safety and soundness of credit unions Issues related to the Military Lending Act Issues related to regulation of Credit Unions as employers Issues related to Housing Finance Reform Issues related to management and operation of Credit Unions Issues related to Large Participants for General-Use Digital Consumer Payment Applications Foreign Account Tax Compliance Act Issues related to minority depository institutions Issues related to diversity, equity, and inclusion initiatives Issues related Credit Card Late Fee Rule H.R. 4868, the Member Business Loan Expansion Act S. 3992, Protecting Access to Credit for Small Businesses Act H.R. 6933, the Expanding Access to Lending Options Act H.R. 3161, the CDFI Fund Transparency Act H.R. 7338, the Rural Credit Access Act of 2024 Issues related to third party vendor authority Issues related to changes to NCUA call report re overdraft/non-sufficient funds fee disclosures Issues related to NCUA request for comment on climate-related financial risk Issues related to Overseas Military Banking Program Issues related to Greenhouse Gas Reduction Fund Issues related to CFPB Junk Fees Regulations Issues related to Federal Home Loan Banks Issues related to Overdraft and Non-sufficient Funds Fees Issues related to Fair Lending Issues related to premium assessments by the National Credit Union Share Insurance Fund Issues related to credit union conversions Issues related to capital reform for credit unions Issues related to Financial inclusion Issues related to Unfair, Deceptive, or Abusive acts or practices Issues related to Credit Union Fintech Investment Authority H.J.Res. 122 - Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to "Credit Card Penalty Fees (Regulation Z) H.R. 7440 Financial Services Innovation Act Issues related to AI in financial services H.R. 7036 Strengthening Cybersecurity for the Financial Sector Act H.R. 7000; S. 3592 Business of Insurance Regulatory Reform Act Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements EPA Greenhouse Gas Reduction Fund Issues related to flood insurance Issues related to Credit Union Service Organizations (CUSO)

Client expense: $2,030,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Environmental Protection Agency (EPA), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), SENATE, Small Business Administration (SBA), Treasury, Dept of

Credit Card Interchange Fees - S. 1838 and H.R. 3881 - Credit Card Competition Act of 2023 Credit Union Loan Maturity Issues Issues related to access to financial services Credit Union Field of Membership issues Issues related to Credit Union Member Business Lending Caps S. 539 - Veterans Member Business Loan Act H.R. 4867 - Veterans Member Business Loan Act Issues related to housing Finance Reform Financial Services Regulatory Relief issues Issues related to Data Security and Data Privacy S. 610 - Credit Union Board Modernization Act S.2860 - Secure and Fair Enforcement Regulation Banking Act S. 1323 - Secure and Fair Enforcement Banking Act S. 2760 - Capping Credit Card Interest Rates Act S. 3538, Close the Shadow Banking Loophole Act Issues related to the National Defense Authorization Act Issues related to the Consumer Financial Protection Board Issues related to consumer financial protection Issues related to Community Development Financial Institutions Issues related to the Community Development Revolving Loan Fund Issues related to Credit Union Loan Maturities Issues related to Digital Assets Credit Union Tax Status Issues related to Financial Services Regulatory Relief Issues related to National Credit Union Administration Examination Procedures Proposed new tax reporting requirements for financial institutions Postal Banking Issues related to FinCEN and appropriations thereto Issues related to privately insured credit unions Issues related to the Federal Reserves new liquidity facility Issues related to the safety and soundness of credit unions Issues related to the Military Lending Act Issues related to regulation of Credit Unions as employers Issues related to Housing Finance Reform Issues related to management and operation of Credit Unions Issues related to Large Participants for General-Use Digital Consumer Payment Applications Foreign Account Tax Compliance Act Issues related to minority depository institutions Issues related to diversity, equity, and inclusion initiatives Issues related Credit Card Late Fee Rule H.R. 4868, the Member Business Loan Expansion Act S. 3992, Protecting Access to Credit for Small Businesses Act H.R. 6933, the Expanding Access to Lending Options Act H.R. 3161, the CDFI Fund Transparency Act H.R. 7338, the Rural Credit Access Act of 2024 Issues related to third party vendor authority Issues related to changes to NCUA call report re overdraft/non-sufficient funds fee disclosures Issues related to NCUA request for comment on climate-related financial risk Issues related to Overseas Military Banking Program Issues related to Greenhouse Gas Reduction Fund Issues related to CFPB Junk Fees Regulations Issues related to Federal Home Loan Banks Issues related to Overdraft and Non-sufficient Funds Fees Issues related to Fair Lending Issues related to premium assessments by the National Credit Union Share Insurance Fund Issues related to credit union conversions Issues related to capital reform for credit unions Issues related to Financial inclusion Issues related to Unfair, Deceptive, or Abusive acts or practices Issues related to Credit Union Fintech Investment Authority H.J.Res. 122 - Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to "Credit Card Penalty Fees (Regulation Z) H.R. 7440 Financial Services Innovation Act Issues related to AI in financial services H.R. 7036 Strengthening Cybersecurity for the Financial Sector Act H.R. 7000; S. 3592 Business of Insurance Regulatory Reform Act Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements EPA Greenhouse Gas Reduction Fund Issues related to flood insurance Issues related to Credit Union Service Organizations (CUSO)

Client expense: $2,030,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Environmental Protection Agency (EPA), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), SENATE, Small Business Administration (SBA), Treasury, Dept of

S. 3538, Close the Shadow Bank Loophole (all provisions).

Client expense: $760,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES

Legislative activities dealing with implementation and compliance burdens under the Dodd-Frank Wall Street Reform Act & Consumer Protection Act affecting industrial banks, industrial loan companies or Morris Plan Banks. FDIC approval process for insuring de novo banks. Issues affecting brokered deposits. Chartering of de novo banks. S. 3538, Close the Shadow Banking Loophole Act, all provisions.

Client expense: Not reported · Firm income: $34,500

Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), SENATE

Issues relating to banking institutions impacting reform. Matters related to Community Reinvestment Act (CRA), Current Expected Credit Loss (CECL); Paycheck Protection Program. Matters relating to financial services regulatory reform, U.S. payments systems, anti-money laundering, beneficial ownership; nominations; and bank climate-related stress tests/scenario analysis. H.R. 2471, the Consolidated Appropriations Act 2022; S. 3844, Economic Continuity and Stability Act; S. 3600 Strengthening American Cybersecurity Act; and H.R. 5991, the Fair Hiring in Banking Act; S.1838, Credit Card Competition Act of 2023; S.2760, Capping Credit Card Interest Rates Act; S.2190, The Recovering Executive Compensation from Unaccountable Practices (RECOUP) Act of 2023. H.R. 7531, Secure Payments Act of 2024; S.3538, Close the Shadow Banking Loophole Act; S.2190, Recovering Executive Compensation Obtained from Unaccountable Practices Act of 2023 (RECOUP Act of 2023).

Client expense: $1,330,000 · Firm income: Not reported

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

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 (FDIC) S. 3638 - Close the Shadow Banking Loophole Act (All Sections) to prevent large companies from gaining access to the federal safety net and escaping federal oversight and supervision and (Senate) S. 3502 and H.R. 3502 - Trigger Leads Abatement Act (All Sections) a bill to prohibit credit reporting agencies from providing a credit report not initiated by a consumer if the report is being provided on the basis that the consumer has had a credit inquiry regarding a home mortgage loan. This practice, known as producing a trigger lead, provides notice to other mortgage lenders that the consumer is seeking a mortgage loan. (Senate and House) Farm Bill - The Passage of a five-year Farm Bill with Community Bank Priorities and without FCS Expansion including higher limits on USDA guaranteed farm loans, quicker turnaround time for USDA Express loan approvals, and without and expansion of the Farm Credit System or their exemption from Dodd-Frank Section 1071 (House and Senate) H.R. 4721 - Main Street Tax Certainty Act (All Sections) legislation to make permanent the tax deduction for qualified business income. (Under current law, the deduction expires after December 31, 2025.) (House) 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 (FDIC) Comment Letter to the FDIC regarding guidelines for establishing standards for corporate governance and risk management - RIN 3064-AF94 (FDIC) CBAI-led joint trades letter with the Illinois Farm Bureau, Illinois Corn Growers Association, Illinois Soybean Growers, and the Grain and Feed Association of Illinois regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), which is 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) Comment Letter to the CFPB regarding Proposed Rule - Fees for Instantly Declined Transactions - Docket ID No. CFPB-2024-0003 and RIN 3170-AB16 (CFPB) Letter to the OCC, Federal Reserve, and FDIC regarding Check Fraud - Prompt and reasonable reimbursements from the largest banks for fraudulently altered return checks (Fraud Returns), and the largest banks opening fraud accounts into which fraud items are being deposited, including - joint supervisory guidance addressed to the largest banks for their apparent management and compliance lapses, enhanced supervision, regulation and enforcement against the largest banks for CDD and CIP compliance (OCC, FDIC, Federal Reserve, House and Senate) Action Alerts - Action Alert - Support Closing the Industrial Loan Company (ILC) Loophole. Support legislation (S. 3538) Close the Shadow Banking Loophole Act (all sections) to prevent large companies from gaining access to the federal safety net and escaping federal oversight and supervision and (Senate) Action Alert - Urge Congress to Pass Farm Bill with Community Bank Priorities and without FCS Expansion including higher limits on USDA guaranteed farm loans, quicker turnaround time for USDA Express loan approvals, and without and expansion of the Farm Credit System or their exemption from Dodd-Frank Section 1071 (House and Senate) Miscellaneous - None

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

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