Predatory Lending Elimination Act

Bank On Certification Program Central Bank Digital Currency Cryptocurrency Deposit Insurance Reform Digital Assets Bank Capital Requirements/Basel Capital Proposal Postal Banking S.1323 & H.R.2891, Secure and Fair Enforcement (SAFE) Banking Act of 2023 H.R.4177 & S.2007, Improving Corporate Governance Through Diversity Act of 2023 H.R.2547, Comprehensive Debt Collection Improvement Act S.3937 & H.R.758, Promoting Access to Capital in Underbanked Communities Act of 2023 H.R. 1533 & S. 2252, Promoting New and Diverse Depository Institutions Act Emergency Capital Investment Issues for CDFI and MDI Institutions H.R.7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on banking UDAAP Supervisory Policies and Adjudication Procedures Community Reinvestment Act Final Rule Applying Community Reinvestment Act to credit unions S.1838 & H.R.3881 Credit Card Competition Act of 2023 S.4760, Digital Commodities Consumer Protection Act of 2022 Merchant Category Codes S.1790, Failed Bank Executives Clawback Act S.293 & H.R.2743, Fair Access to Banking Act H.R.2799, Expanding Access to Capital Act of 2023 H.R.2603, To require the Securities and Exchange Commission to revise certain thresholds related to smaller reporting companies, accelerated filers, and large accelerated filers, and for other purposes H.R.2798, Consumer Financial Protection Bureau Transparency and Accountability Reform Act H.R.1382, TABS Act of 2023 H.R.1411, Consumer Financial Protection Bureau-Inspector General Reform Act H.R.2489, the Consumer Financial Protection Bureau Dual Mandate and Economic Analysis Act H.R.1313, the Transparency in Consumer Financial Protection Bureau Cost-Benefit Analysis Act H.R.1719, Making the Consumer Financial Protection Bureau Accountable to Small Business Act S.1362, the Transparency in Consumer Financial Protection Bureau Cost-Benefit Analysis Act H.R.490, Federal Infrastructure Bank Act of 2023 H.R.4868, Member Business Loan Expansion Act H.R.4035, Protecting Small Business Information Act of 2023 S.2760, Capping Credit Card Interest Rates Act H.R.5485, Financial Privacy Act of 2023 H.R.5524, Foreign Affiliate Sharing Pilot Program H.R.5403, Central Bank Digital Currency Anti-Surveillance Act H.R.5741, Uniform Treatment of Custodial Assets Act S.2860, Secure and Fair Enforcement Regulation (SAFER) Banking Act H.R.4763, Financial Innovation and Technology for the 21st Century Act H.R.4766, Clarity for Payment Stablecoins Act of 2023 S.2190, Recovering Executive Compensation Obtained Through Unaccountable Practices (RECOUP) Act of 2023 S.2251, Federal Information Security Modernization Act H.R.3398, Safe Access to Cash Act of 2023 S.3549, the Predatory Lending Elimination Act H.R.6789, Rectifying UDAAP Act H.R.1810, Bank Loan Privacy Act H.R.1806/S.1159, Small Lender Act H.R.4346, Small Bank Holding Company Relief Act of 2023 H.R.4198, Protecting Consumers from Abusive Mortgage Leads Act Regulation II: Debit Card Interchange Fees and Routing Implementation of Dodd-Frank Act Section 1033: Final Rule on Personal Financial Data Rights Merger and Acquisition Policy S.3554, Financial Artificial Intelligence Risk Reduction Act Artificial Intelligence Risk Management, Regulation, and Innovation CDFI Certification Update H.R.7531 & S.4570, Secure Payments Act of 2024 H.R.7437, Fostering Use of Technology to Uphold Regulatory Effectiveness in Supervision Act (FUTURES Act) H.R.4206, Bank Safety Act H.J.Res.122 & S.J.Res.70, Providing for Congressional disapproval under Chapter 8 of Title 5, U.S. Code, of the rule submitted by the Consumer Financial Protection Bureau related to Credit Card Penalty Fees (Reg Z) Notice of Proposed Rulemaking for Debit Card Interchange Fees and Routing (Reg II) Department of Labor Fiduciary Rule H.J.Res.140, 141, 142, and 143-Congressional Review Act Resolutions of Disapproval of the Department of Labor Fiduciary Rule S.J.Res.79, Congressional Review Act Resolution of Disapproval of the Department of Labor Fiduciary Rule Federal Reserve Discount Window and Emergency Lending Authority Guidelines for Establishing Standards for Corporate Governance and Risk Management for Covered Institutions with Total Consolidated Assets of $10 Billion or More CFPB Larger Participant of a Market for General-Use Digital Consumer Payment Applications H.R.8337, Bank Resilience and Regulatory Improvement Act H.R.8338, Clarity in Lending Act H.R.8288, Bringing the Discount Window into the 21st Century Act H.R.8287, Stress Testing Accountability and Transparency Act H.R.8264, Bank Supervision Appeals Improvement Act of 2024 H.R.8356, Small Dollar Loan Certainty Act H.R.7403, Bank Failure Prevention Act of 2024H.R.7437, Fostering the Use of Technology to Uphold Regulatory Effectiveness in Supervision (FUTURES) Act H.R.4206, Bank Safety Act Tokenization of Assets Fraud Issues Peer-To-Peer Payment Fraud FDIC Proposed Guidelines for Corporate Governance and Risk Management for Banks Over $10 Billion in Assets Pilot program allowing Freddie Mac to purchase single family closed-end second mortgages National Bank Act & Defending Dual Banking System S. 4943/H.R. 9303 Protecting Consumers From Payment Scams Act Financial Data Transparency Act Rulemaking FDIC Brokered Deposit Proposal H.R.7420 Ensuring Diversity in Community Banking Act CFPB Overdraft Rule H.R. 4212/S. 1938, Middle Class Mortgage Insurance Premium Act

Client expense: $1,570,000 · Firm income: Not reported

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

Proposals that would alter the vehicle sales, advertising and financing process Legislative proposals to cap the interest rate on extensions of consumer credit and redefine the APR (S. 3549,"The Predatory Lending Elimination Act") Proposals regarding dealer participation, consumer discounts and voluntary protection products. Proposals regarding Section 1071 small business data collection Proposals related to telemarketing and advertising Legislative proposals regarding Congressional oversight of the CFPB (No bill) Proposals for the FDIC to reconsider the proposed Parent Companies of Industrial Banks and Industrial Loan Companies (ILC) rule as it will adversely impact the vehicle industry by effectively prohibiting the creation of new industrial banks.

Client expense: $1,231,000 · Firm income: Not reported

All legislation related to consumer lending regulation and consumer lending policy. S. 1323, The SAFE Banking Act of 2023 H.R. 2891, The SAFE Banking Act of 2023 S, 293, The Fair Access to Banking Act H.R. 2743, The Fair Access to Banking Act S. 2860, The SAFER Banking Act S. 2730, The Protecting Consumers from Unreasonable Credit Rates Act of 2023 S. 3549, The Predatory Lending Elimination Act

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Legislative proposals impacting banking services for financial services providers; Payday, Vehicle Title, and Certain High-Cost Installment Loans; Federal policy relating to anticipated Consumer Financial Protection Bureau regulation of consumer financial services including payday and auto title lending, and regulatory process; H.R.1382, TABS Act of 2023; H.R.1165, Data Privacy Act of 2023; H.R.2798, CFPB Transparency and Accountability Reform Act; S.3549, Predatory Lending Elimination Act; H.R.7428, Earned Wage Access Consumer Protection Act; H.R.10036, Civil Investigative Demand Reform Act of 2024.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 3815: Improving Disclosure for Investors Act of 2024 H.R. 7780: Safeguarding Investment Options for Retirement Act S. 3179: Stop Woke Investing Act H.J. Res. 120: a resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Financial Stability Oversight Council (FSOC) relating to Guidance on Non-Bank Financial Company Determinations H.J. Res. 127/S.J. Res. 72: a resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Securities and Exchange Commission relating to the Enhancement and Standardization of Climate-Related Disclosures for Investors S. 3549: Predatory Lending Elimination Act Docket No. CFPB-2023-0053: Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

All legislation related to consumer lending regulation and consumer lending policy. S. 1323, The SAFE Banking Act of 2023 H.R. 2891, The SAFE Banking Act of 2023 S, 293, The Fair Access to Banking Act H.R. 2743, The Fair Access to Banking Act S. 2860, The SAFER Banking Act S. 2730, The Protecting Consumers from Unreasonable Credit Rates Act of 2023 S. 3549, The Predatory Lending Elimination Act

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Proposals that would alter the vehicle sales, advertising and financing process Legislative proposals to cap the interest rate on extensions of consumer credit and redefine the APR (S. 3549,"The Predatory Lending Elimination Act") Proposals regarding dealer participation, consumer discounts and voluntary protection products. Proposals regarding Section 1071 small business data collection Proposals related to telemarketing and advertising Legislative proposals regarding Congressional oversight of the CFPB (No bill)

Client expense: $1,649,000 · Firm income: Not reported

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

Bank On Certification Program Central Bank Digital Currency Cryptocurrency Deposit Insurance Digital Assets Bank Capital Requirements/Basel Capital Proposal Postal Banking S.1323 & H.R.2891, Secure and Fair Enforcement (SAFE) Banking Act of 2023 H.R.4177 & S.2007, Improving Corporate Governance Through Diversity Act of 2023 H.R.2547, Comprehensive Debt Collection Improvement Act S.3937 & H.R.758, Promoting Access to Capital in Underbanked Communities Act of 2023 H.R. 1533 & S. 2252, Promoting New and Diverse Depository Institutions Act Emergency Capital Investment Issues for CDFI and MDI Institutions H.R.7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on banking UDAAP Supervisory Policies and Adjudication Procedures Community Reinvestment Act Final Rule Deposit Insurance Issues S.1838 & H.R.3881 Credit Card Competition Act of 2023 S.4760, Digital Commodities Consumer Protection Act of 2022 Merchant Category Codes S.1790, Failed Bank Executives Clawback Act S.293 & H.R.2743, Fair Access to Banking Act H.R.2799, Expanding Access to Capital Act of 2023 H.R.2603, To require the Securities and Exchange Commission to revise certain thresholds related to smaller reporting companies, accelerated filers, and large accelerated filers, and for other purposes H.R.2798, Consumer Financial Protection Bureau Transparency and Accountability Reform Act H.R.1382, TABS Act of 2023 H.R.1411, Consumer Financial Protection Bureau-Inspector General Reform Act H.R.2489, the Consumer Financial Protection Bureau Dual Mandate and Economic Analysis Act H.R.1313, the Transparency in Consumer Financial Protection Bureau Cost-Benefit Analysis Act H.R.1719, Making the Consumer Financial Protection Bureau Accountable to Small Business Act S.1362, the Transparency in Consumer Financial Protection Bureau Cost-Benefit Analysis Act H.R.490, Federal Infrastructure Bank Act of 2023 H.R.4868, Member Business Loan Expansion Act H.R.4035, Protecting Small Business Information Act of 2023 S.2760, Capping Credit Card Interest Rates Act H.R.5485, Financial Privacy Act of 2023 H.R.5524, Foreign Affiliate Sharing Pilot Program H.R.5403, Central Bank Digital Currency Anti-Surveillance Act H.R.5741, Uniform Treatment of Custodial Assets Act S.2860, Secure and Fair Enforcement Regulation (SAFER) Banking Act H.R.4763, Financial Innovation and Technology for the 21st Century Act H.R.4766, Clarity for Payment Stablecoins Act of 2023 S.2190, Recovering Executive Compensation Obtained Through Unaccountable Practices (RECOUP) Act of 2023 S.2251, Federal Information Security Modernization Act H.R.3398, Safe Access to Cash Act of 2023 S.3549, the Predatory Lending Elimination Act H.R.6789, Rectifying UDAAP Act H.R.1810, Bank Loan Privacy Act H.R.1806/S.1159, Small Lender Act H.R.4346, Small Bank Holding Company Relief Act of 2023 H.R.4198, Protecting Consumers from Abusive Mortgage Leads Act Regulation II: Debit Card Interchange Fees and Routing Implementation of Dodd-Frank Act Section 1033: Proposed Rule on Personal Financial Data Rights Merger and Acquisition Policy S.3554, Financial Artificial Intelligence Risk Reduction Act Artificial Intelligence Risk Management, Regulation, and Innovation CDFI Certification Update H.R.7531 & S.4570, Secure Payments Act of 2024 H.R.7437, Fostering Use of Technology to Uphold Regulatory Effectiveness in Supervision Act (FUTURES Act) H.R.4206, Bank Safety Act H.J.Res.122 & S.J.Res.70, Providing for Congressional disapproval under Chapter 8 of Title 5, U.S. Code, of the rule submitted by the Consumer Financial Protection Bureau related to Credit Card Penalty Fees (Reg Z) Notice of Proposed Rulemaking for Debit Card Interchange Fees and Routing (Reg II) Department of Labor Fiduciary Rule H.J.Res.140, 141, 142, and 143-Congressional Review Act Resolutions of Disapproval of the Department of Labor Fiduciary Rule S.J.Res.79, Congressional Review Act Resolution of Disapproval of the Department of Labor Fiduciary Rule Federal Reserve Discount Window and Emergency Lending Authority Guidelines for Establishing Standards for Corporate Governance and Risk Management for Covered Institutions with Total Consolidated Assets of $10 Billion or More CFPB Larger Participant of a Market for General-Use Digital Consumer Payment Applications H.R.8337, Bank Resilience and Regulatory Improvement Act H.R.8338, Clarity in Lending Act H.R.8288, Bringing the Discount Window into the 21st Century Act H.R.8287, Stress Testing Accountability and Transparency Act H.R.8264, Bank Supervision Appeals Improvement Act of 2024 H.R.8356, Small Dollar Loan Certainty Act H.R.7403, Bank Failure Prevention Act of 2024H.R.7437, Fostering the Use of Technology to Uphold Regulatory Effectiveness in Supervision (FUTURES) Act H.R.4206, Bank Safety Act Tokenization of Assets Fraud Issues Peer-To-Peer Payment Fraud FDIC Proposed Guidelines for Corporate Governance and Risk Management for Banks Over $10 Billion in Assets Pilot program allowing Freddie Mac to purchase single family closed-end second mortgages National Bank Act & Defending Dual Banking System S. 4943/H.R. 9303 Protecting Consumers From Payment Scams Act Financial Data Transparency Act Rulemaking FDIC Brokered Deposit Proposal H.R.7420 Ensuring Diversity in Community Banking Act

Legislative proposals impacting banking services for financial services providers; Payday, Vehicle Title, and Certain High-Cost Installment Loans; Federal policy relating to anticipated Consumer Financial Protection Bureau regulation of consumer financial services including payday and auto title lending, and regulatory process; H.R.1382, TABS Act of 2023; H.R.1165, Data Privacy Act of 2023; H.R.2798, CFPB Transparency and Accountability Reform Act; S.3549, Predatory Lending Elimination Act; H.R.7428, Earned Wage Access Consumer Protection Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 3815: Improving Disclosure for Investors Act of 2024 H.R. 7780: Safeguarding Investment Options for Retirement Act S. 3179: Stop Woke Investing Act H.J. Res. 120: a resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Financial Stability Oversight Council (FSOC) relating to Guidance on Non-Bank Financial Company Determinations H.J. Res. 127/S.J. Res. 72: a resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Securities and Exchange Commission relating to the Enhancement and Standardization of Climate-Related Disclosures for Investors S. 3549: Predatory Lending Elimination Act Docket No. CFPB-2023-0053: Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Proposals that would alter the vehicle sales, advertising and financing process Legislative proposals to cap the interest rate on extensions of consumer credit and redefine the APR (S. 3549,"The Predatory Lending Elimination Act") Proposals regarding dealer participation, consumer discounts and voluntary protection products. Proposals regarding the Safeguards Rule Proposals regarding Section 1071 small business data collection Proposals related to telemarketing and advertising Legislative proposals regarding Congressional oversight of the CFPB (No bill)

Client expense: $1,168,000 · Firm income: Not reported

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

Bank On Certification Program Central Bank Digital Currency Cryptocurrency Deposit Insurance Digital Assets Bank Capital Requirements/Basel Capital Proposal Postal Banking S.1323 & H.R.2891, Secure and Fair Enforcement (SAFE) Banking Act of 2023 H.R.4177 & S.2007, Improving Corporate Governance Through Diversity Act of 2023 H.R.2547, Comprehensive Debt Collection Improvement Act S.3937 & H.R.758, Promoting Access to Capital in Underbanked Communities Act of 2023 H.R. 1533 & S. 2252, Promoting New and Diverse Depository Institutions Act Emergency Capital Investment Issues for CDFI and MDI H.R.7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on banking UDAAP Supervisory Policies and Adjudication Procedures Community Reinvestment Act Final Rule Deposit Insurance Issues S.1838 & H.R.3881 Credit Card Competition Act of 2023 S.4760, Digital Commodities Consumer Protection Act of 2022 Merchant Category Codes S.1790, Failed Bank Executives Clawback Act S.293 & H.R.2743, Fair Access to Banking Act H.R.2799, Expanding Access to Capital Act of 2023 H.R.2603, To require the Securities and Exchange Commission to revise certain thresholds related to smaller reporting companies, accelerated filers, and large accelerated filers, and for other purposes H.R.2798, Consumer Financial Protection Bureau Transparency and Accountability Reform Act H.R.1382, TABS Act of 2023 H.R.1411, Consumer Financial Protection Bureau-Inspector General Reform Act H.R.2489, the Consumer Financial Protection Bureau Dual Mandate and Economic Analysis Act H.R.1313, the Transparency in Consumer Financial Protection Bureau Cost-Benefit Analysis Act H.R.1719, Making the Consumer Financial Protection Bureau Accountable to Small Business Act S.1362, the Transparency in Consumer Financial Protection Bureau Cost-Benefit Analysis Act H.R.490, Federal Infrastructure Bank Act of 2023 H.R.4868, Member Business Loan Expansion Act H.R.4035, Protecting Small Business Information Act of 2023 S.2760, Capping Credit Card Interest Rates Act H.R.5485, Financial Privacy Act of 2023 H.R.5524, Foreign Affiliate Sharing Pilot Program H.R.5403, Central Bank Digital Currency Anti-Surveillance Act H.R.5741, Uniform Treatment of Custodial Assets Act S.2860, Secure and Fair Enforcement Regulation (SAFER) Banking Act H.R.4763, Financial Innovation and Technology for the 21st Century Act H.R.4766, Clarity for Payment Stablecoins Act of 2023 S.2190, Recovering Executive Compensation Obtained Through Unaccountable Practices (RECOUP) Act of 2023 S.2251, Federal Information Security Modernization Act H.R.3398, Safe Access to Cash Act of 2023 S.3549, the Predatory Lending Elimination Act H.R.6789, Rectifying UDAAP Act H.R.1810, Bank Loan Privacy Act H.R.1806/S.1159, Small Lender Act H.R.4346, Small Bank Holding Company Relief Act of 2023 H.R.4198, Protecting Consumers from Abusive Mortgage Leads Act Regulation II: Debit Card Interchange Fees and Routing Implementation of Dodd-Frank Act Section 1033: Proposed Rule on Personal Financial Data Rights Merger and Acquisition Policy S.3554, Financial Artificial Intelligence Risk Reduction Act CDFI Certification Update H.R.7531 & S.4570, Secure Payments Act of 2024 H.R.7437, Fostering Use of Technology to Uphold Regulatory Effectiveness in Supervision Act (FUTURES Act) H.R.4206, Bank Safety Act H.J.Res.122 & S.J.Res.70, Providing for Congressional disapproval under Chapter 8 of Title 5, U.S. Code, of the rule submitted by the Consumer Financial Protection Bureau related to Credit Card Penalty Fees (Reg Z) Notice of Proposed Rulemaking for Debit Card Interchange Fees and Routing (Reg II) Department of Labor Fiduciary Rule H.J.Res.140, 141, 142, and 143-Congressional Review Act Resolutions of Disapproval of the Department of Labor Fiduciary Rule S.J.Res.79, Congressional Review Act Resolution of Disapproval of the Department of Labor Fiduciary Rule Federal Reserve Discount Window and Emergency Lending Authority Guidelines for Establishing Standards for Corporate Governance and Risk Management for Covered Institutions with Total Consolidated Assets of $10 Billion or More CFPB Larger Participant of a Market for General-Use Digital Consumer Payment Applications H.R.8337, Bank Resilience and Regulatory Improvement Act H.R.8338, Clarity in Lending Act H.R.8288, Bringing the Discount Window into the 21st Century Act H.R.8287, Stress Testing Accountability and Transparency Act H.R.8264, Bank Supervision Appeals Improvement Act of 2024 H.R.8356, Small Dollar Loan Certainty Act H.R.7403, Bank Failure Prevention Act of 2024H.R.7437, Fostering the Use of Technology to Uphold Regulatory Effectiveness in Supervision (FUTURES) Act H.R.4206, Bank Safety Act Tokenization of Assets Fraud Issues FDIC Proposed Guidelines for Corporate Governance and Risk Management for Banks Over $10 Billion in Assets Pilot program allowing Freddie Mac to purchase single family closed-end second mortgages National Bank Act & Defending Dual Banking System

Legislative proposals impacting banking services for financial services providers; Payday, Vehicle Title, and Certain High-Cost Installment Loans; Federal policy relating to anticipated Consumer Financial Protection Bureau regulation of consumer financial services including payday and auto title lending, and regulatory process; H.R.1382, TABS Act of 2023; H.R.1165, Data Privacy Act of 2023; H.R.2798, CFPB Transparency and Accountability Reform Act; S.3549, Predatory Lending Elimination Act; H.R.7428, Earned Wage Access Consumer Protection Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

All legislation related to consumer lending regulation and consumer lending policy. S. 1323, The SAFE Banking Act of 2023 H.R. 2891, The SAFE Banking Act of 2023 S, 293, The Fair Access to Banking Act H.R. 2743, The Fair Access to Banking Act S. 2860, The SAFER Banking Act S. 2730, The Protecting Consumers from Unreasonable Credit Rates Act of 2023 S. 3549, The Predatory Lending Elimination Act

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 3815: Improving Disclosure for Investors Act of 2024 H.R. 7780: Safeguarding Investment Options for Retirement Act S. 3179: Stop Woke Investing Act H.J. Res. 120: a resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Financial Stability Oversight Council (FSOC) relating to Guidance on Non-Bank Financial Company Determinations H.J. Res. 127/S.J. Res. 72: a resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Securities and Exchange Commission relating to the Enhancement and Standardization of Climate-Related Disclosures for Investors S. 3549: Predatory Lending Elimination Act Docket No. CFPB-2023-0053: Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

All legislation related to consumer lending regulation and consumer lending policy. S. 1323, The SAFE Banking Act of 2023 H.R. 2891, The SAFE Banking Act of 2023 S, 293, The Fair Access to Banking Act H.R. 2743, The Fair Access to Banking Act S. 2860, The SAFER Banking Act S. 2730, The Protecting Consumers from Unreasonable Credit Rates Act of 2023 S. 3549, The Predatory Lending Elimination Act

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Proposals that would alter the vehicle sales, advertising and financing process Legislative proposals to cap the interest rate on extensions of consumer credit and redefine the APR (S. 3549,"The Predatory Lending Elimination Act") Interpretation of the scope of the vehicle financing exclusion to the Military Lending Act Proposals regarding dealer participation, consumer discounts and voluntary protection products. Proposals regarding the Safeguards Rule Proposals regarding Section 1071 small business data collection Proposals related to telemarketing and advertising Proposals regarding capital requirements for financial institutions.

Client expense: $1,441,000 · Firm income: Not reported

Legislative proposals impacting banking services for financial services providers; Payday, Vehicle Title, and Certain High-Cost Installment Loans; Federal policy relating to anticipated Consumer Financial Protection Bureau regulation of consumer financial services including payday and auto title lending, and regulatory process; H.R.1382, TABS Act of 2023; H.R.1165, Data Privacy Act of 2023; H.R.2798, CFPB Transparency and Accountability Reform Act; S.3549, Predatory Lending Elimination Act; H.R.7428, Earned Wage Access Consumer Protection Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Bank On Central Bank Digital Currency Cryptocurrency Deposit Insurance Digital Assets Bank Capital Requirements/Basel Capital Proposal Postal Banking S.1323 & H.R.2891, Secure and Fair Enforcement (SAFE) Banking Act of 2023 H.R. 4177 & S. 2007, Improving Corporate Governance Through Diversity Act of 2023 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 758, Promoting Access to Capital in Underbanked Communities Act of 2023 H.R.4590, Promoting New and Diverse Depository Institutions Act H.R. 1533, Promoting New and Diverse Depository Institutions Act Emergency Capital Investment Issues for CDFI and MDI H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on Banking UDAAP Supervisory Policies and Adjudication Procedures Community Reinvestment Act Final Rule Deposit Insurance Issues S.1838, Credit Card Competition Act of 2023 H.R. 3881, Credit Card Competition Act of 2023 S.4760, Digital Commodities Consumer Protection Act of 2022 Merchant Category Codes S.1790, Failed Bank Executives Clawback Act S.293 & H.R. 2743, Fair Access to Banking Act H.R. 2799, Expanding Access to Capital Act of 2023 H.R. 2603, To require the Securities and Exchange Commission to revise certain thresholds related to smaller reporting companies, accelerated filers, and large accelerated filers, and for other purposes H.R. 2798, Consumer Financial Protection Bureau Transparency and Accountability Reform Act H.R. 1382, TABS Act of 2023 H.R. 1411, Consumer Financial Protection Bureau-Inspector General Reform Act H.R. 2489, the Consumer Financial Protection Bureau Dual Mandate and Economic Analysis Act H.R. 1313, the Transparency in Consumer Financial Protection Bureau Cost-Benefit Analysis Act H.R. 1719, Making the Consumer Financial Protection Bureau Accountable to Small Business Act S.1362, the Transparency in Consumer Financial Protection Bureau Cost-Benefit Analysis Act H.R. 490, Federal Infrastructure Bank Act of 2023 H.R. 4868, Member Business Loan Expansion Act H.R. 4035, Protecting Small Business Information Act of 2023 S.2760, Capping Credit Card Interest Rates Act H.R. 5485, Financial Privacy Act of 2023 H.R. 5524, Foreign Affiliate Sharing Pilot Program H.R. 5403, Central Bank Digital Currency Anti-Surveillance Act H.R. 5741, Uniform Treatment of Custodial Assets Act S. 2860, Secure and Fair Enforcement Regulation (SAFER) Banking Act H.R. 4763, Financial Innovation and Technology for the 21st Century Act H.R. 4766, Clarity for Payment Stablecoins Act of 2023 S. 2190, Recovering Executive Compensation Obtained Through Unaccountable Practices (RECOUP) Act of 2023 S. 2251, Federal Information Security Modernization Act H.R. 3398, Safe Access to Cash Act of 2023 S. 3549, the Predatory Lending Elimination Act H.R. 6789, Rectifying UDAAP Act H.R. 1810, Bank Loan Privacy Act H.R. 1806/S. 1159, Small Lender Act H.R. 4346, Small Bank Holding Company Relief Act of 2023 H.R. 4198, Protecting Consumers from Abusive Mortgage Leads Act Regulation II: Debit Card Interchange Fees and Routing Implementation of Dodd-Frank Act Section 1033:Proposed Rule on Personal Financial Data Rights Department of Labor Retirement Security Rule: Definition of an Investment Advice Fiduciary (Fiduciary Rule) S.3554, Financial Artificial Intelligence Risk Reduction Act CDFI Certification Update H.R. 7531, Secure Payments Act of 2024 H.R. 7437, Fostering Use of Technology to Uphold Regulatory Effectiveness in Supervision Act (FUTURES Act) H.R. 4206, Bank Safety Act H.J. Res. 122/S.J, Res. 70, Providing for Congressional disapproval under Chapter 8 of Title 5, U.S. Code, of the rule submitted by the Consumer Financial Protection Bureau related to Credit Card Penalty Fees (Reg Z) H.R. 6789, Rectifying UDAAP Act Notice of Proposed Rulemaking for Debit Card Interchange Fees and Routing (Reg II) Department of Labor Fiduciary Proposal Department of Labor Overtime Proposal Federal Reserve Discount Window and Emergency Lending Authority Guidelines for Establishing Standards for Corporate Governance and Risk Management for Covered Institutions with Total Consolidated Assets of $10 Billion or More CFPB Larger Participant of a Market for General-Use Digital Consumer Payment Applications

Proposals that would alter the vehicle sales, advertising and financing process Legislative proposals to cap the interest rate on extensions of consumer credit and redefine the APR (S. 3549,"The Predatory Lending Elimination Act") Interpretation of the scope of the vehicle financing exclusion to the Military Lending Act Proposals regarding dealer participation, consumer discounts and voluntary protection products. Proposals regarding the Safeguards Rule Proposals regarding Section 1071 small business data collection Proposals related to telemarketing and advertising Proposals regarding capital requirements for financial institutions.

Client expense: $2,094,000 · Firm income: Not reported

CFPB authority and funtions, related to structure and supervision, research and enforcement priorities Increased supervision and enforcement of unregulated "fintech" products like BNPL and faux EWA providers Eliminating excessive banking fees, including overdraft CFPB Examination of nonbank mortgage, private loan, and payday loan entities Opposition to FSGG Appropriations language restricting CFPB and FTC Junk fees imposed by providers of consumer financial products and services Supporting a CFPB forced arbitration rulemaking H.R.2798 - CFPB Transparency and Accountability Reform Act, a bill to place the CFPB in appropriations, enact a commission structiuon, and other revisions S.3549 - Predatory Lending Elimination Act - A bill to amend the Truth in Lending Act to extend the consumer credit protections provided to members of the Armed Forces and their dependents under title 10, United States Code, to all consumers. S.3538 - Close the Shadow Banking Loophole Act - A bill to reform the regulation of industrial loan companies and their parent companies S.___ / H.R.___ - A bill to prohibit a financial institution from engaging in unfair or deceptive acts in connection with overdraft coverage

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

Protect the credit union tax exemption; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their nearly 140 million members; Support regulatory relief for credit unions; Provide guidance or rulemakings rather than rule through enforcement; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; Support increase in funding for CDFI Fund, MDIs, and the CDRLF; Support extending GLBA-like data security measures to retailers and fintechs; Support recognizing GLBA compliance in any privacy legislation; Oppose private right of action in data privacy legislation; Support NCUA as credit unions sole data privacy regulator; Oppose opt-in requirement for use of non-public personal information in data privacy legislation; Support federal preemption of state data privacy laws; Oppose NCUA examination authority for 3rd party vendors; Oppose NCUA adopting a dedicated consumer compliance examination; Support extended NCUA examination cycle; Support NCUA Central Liquidity Facility (CLF) improvements; Support vendor information sharing among financial regulators; Support NCUA independence as regulator and insurer; Oppose unsustainable NCUA budget growth; Support increased NCUA assistance for MDI credit unions; Support adjusting Dodd-Frank Act thresholds for inflation; Support legislative action to limit Regulation E liability; Support fair distribution of Regulation E error resolution responsibilities; Support greater investment authorities for credit unions; Support expansion of Low-Income Housing Tax Credit; Support publication of list of entities with access to Federal Reserve Bank accounts and services; Support legislative action to clarify CFPBs UDAAP authority; Support parity in credit union and bank federal deposit insurance levels; Oppose increased NCUA authority to charge share insurance premiums; Oppose SBA direct lending authority; Oppose fintech participation in SBA lending programs; Prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; Support increased CFPB transparency in rulemaking, supervision, and enforcement; Support CFPB coordination with NCUA in policymaking; Support CFPB basing policy on thorough research and data analysis; CFPB should engage in interagency coordination on Section 1033 consumer access to financial records rulemaking; Oppose CFPBs characterization of regulated and disclosed financial services fees as junk fees; CFPB should explore streamlining required fee disclosures; Oppose mandatory grace period for credit card late payments; CFPB should clarify UDAAP authority; CFPB should respect GLBAs data security regulatory structure; CFPB should limit impact and burden from final rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); Support prohibiting CFPB expending funds to implement the Section 1071 Small Business Lending Data Collection final rule (RIN: 3170-AA09); Improve examination coordination between CFPB and NCUA; Support CFPB exercise of larger participant authority to oversee fintech companies; Support clear regulatory framework for digital assets to encourage responsible innovation and permit credit union participation; Support CDFI Fund transparency on certification changes; Oppose changes to CDFI Fund certification process; Support Congressional oversight of SBAs Affiliation and Small Business Lending Company final rules; Support legislation to limit impact of SBAs Affiliation and Small Business Lending Company final rules; Support tax deduction for mortgage insurance premiums; Support modification or removal of the credit union member business lending cap; Support increasing credit union loan maturity limits; Support allowing credit unions to add underserved areas to their FOM; Support removing service area requirement for FOM expansion; Support increasing the credit union interest rate ceiling; Oppose national all-in interest rate cap; Oppose expanding the Fair Debt Collection Practices Act to cover business loans; Support credit union Community Reinvestment Act exemption; Support regulator-approved credit union mergers; Support regulations adhering to intent of the Fair Credit Reporting Act; Support regulation of credit reporting agencies and credit repair organizations; Oppose legislation granting for-profit banks nominal leases on military installations; Support credit union access to nominal leases on military installations; Support alternative credit scoring models; Oppose exclusion of accurate information from credit reports; Support FinCEN funding; Support FinCEN oversight; Support increasing SAR and CTR thresholds; Support disbursal of ECIP funding; Oppose NCUA acting as a climate regulator; Support credit union eligibility for the Greenhouse Gas Reduction Fund; Support Congressional oversight of the Federal Reserve Overnight Reverse Repo Facility; FCC should tailor robocall and robotext regulations to allow credit unions to serve their members; Support placing CFPB under regular appropriations process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs and consider wealth-building home loan pilot programs; Oppose increase in FHFA guarantee fees; Support elimination of guarantee fees for credit union mortgages; Support regulation of fintechs in mortgage lending; Support alternative credit scoring models; Oppose development of a CBDC; Support prevention of an NFIP lapse; Support improving veterans access to capital by exempting credit unions business loans to veterans from the credit union member business lending cap; Support expanding the definition of Community Financial Institutions (CFIs) in the Federal Home Loan Bank Act (FHLB Act) to include credit unions and Treasury-certified non-depository community development financial institutions; Support government guarantees to stabilize mortgage-backed securities market; Support pilot programs for wealth-building home loans and zero-down mortgages; Support quality- rather than quantity-based GSE loan pricing; Oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; Support parity for credit unions related to stablecoin regulation; Treasury should address the demand for coins to help consumers who rely on cash transactions; Support addressing appraisal bias and modernize the appraisal process for consistency; Support easing requirements for de novo credit unions; Support providing flexibility for credit unions to issue subordinated debt; Support improvements to ease the process for forgiveness of PPP loans to small businesses; Oppose limits on fee income for credit unions including courtesy pay; Support limiting burdens of HMDA rule on credit unions; CFPB should remove unnecessary and unused data points related to HMDA reporting; Support permanently increasing reporting thresholds for open- and closed-end loans; Support permanent adoption of CFPBs expired temporary relief of E-SIGN regulation; Oppose Federal Reserve proposal to decrease debit interchange fee cap (Docket No. R‐1818); Support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support Credit Union Board Modernization Act (H.R. 582; S. 610); Support Promoting Access to Capital in Underbanked Communities Act (H.R. 758); Support Promoting New and Diverse Depository Institutions Act (H.R. 1533; S. 2252); Support Consumer Financial Protection Commission Act (H.R. 1410); Support SECURE Notarization Act (H.R. 1059; S. 1212); Support Prohibiting IRS Financial Surveillance Act (H.R. 1010; S. 453); Support CBDC Anti-Surveillance State Act (H.R. 1122; H.R. 5403); Support Data Privacy Act (H.R. 1165); Support Veterans Member Business Loan Act (S. 539; H.R. 4867); Support NCUA Central Liquidity Facility Enhancements (S. 544); Support Neighborhood Homes Investment Act (S. 657); Support CDFI Bond Guarantee Program Improvement Act (S. 869); Support Small LENDER Act (H.R. 1806); Support Transparency in CFPB Cost-Benefit Analysis Act (H.R. 1313); Support Making the CFPB Accountable to Small Businesses Act (H.R. 1749); Support Resolution of Disapproval of the CFPBs Section 1071 final rule (H.J.Res. 50; H.J.Res. 66; H.J.Res. 85; S.J.Res. 32) Support CFPB Transparency and Accountability Reform Act (H.R. 2798); Support SAFE Banking Act (H.R. 2891; S. 1323); Support CDFI Fund Transparency Act (H.R. 3161; S. 2674); Support Building Credit Access for Veterans Act (H.R. 1266); Support Increasing Financial Regulatory Accountability and Transparency Act (H.R. 3556); Support Middle Class Borrower Protection Act (H.R. 3564; S. 2296); Support Digital Dollar Pilot Prevention Act (H.R. 3712); Oppose Credit Card Competition Act (H.R. 3881; S. 1838); Support Member Business Loan Expansion Act (H.R. 4868); Oppose Senate NDAA amendments on interchange (#177; #425); Support Clarity for Payment Stablecoins Act (H.R. 4766); Support Senate NDAA amendment on financial literacy (#206); Support Homes for Every Local Protector, Educator, and Responder (HELPER) Act (H.R. 3170; S. 1514); Oppose Senate appropriations amendment on interchange (#1161); Oppose Senate appropriations amendments on interest rate caps (#1225; #1285); Oppose Capping Credit Card Interest Rates Act (S. 2760); Support SAFER Banking Act (S. 2860); Oppose Amendment #117 to H.R. 4664; Support Amendment #174 to H.R. 4664; Support provisions of H.R. 4664 to place CFPB under the regular appropriations process and restructure the Bureau to a bipartisan commission; Support Rectifying UDAAP Act (H.R. 6789); Support Close the Shadow Banking Loophole Act (S. 3538); Oppose Predatory Lending Elimination Act (S. 3549); Comments to NCUA on OMB Number: 3133-NEW supporting streamlined speaker request forms and increased transparency in speaker request process; Comments to Office of the National Cyber Director on RIN: 0301-AA00 supporting regulatory harmonization and minimizing overlapping or conflicting requirements; Comments to CFPB on Outline of FCRA Proposals supporting adherence to Congressional intent and reissuance of proposals with more detail and specificity; Comments to Department of Labor on RIN 1235-AA39 opposing automatic adjustments and encouraging accommodation of smaller credit unions; Comments to NCUA on proposed 2024-2025 budget opposing unsustainable budget increases and encouraging cost-savings and transparency; Comments to OMB on OMB-2023-0020 supporting increased transparency on agencies use of artificial intelligence technology; Comments to NCUA on Docket No. NCUA-2023-0082 supporting simplification of share insurance for trust accounts; Comments to CFPB on Docket No. CFPB-2023-0052 opposing the proposal and urging CFPB to reduce burden on credit unions and adopt a safe harbor for data providers; Support FHFA publishing data and analysis related to credit score model validation; Support regulatory cost-benefit analysis that includes cumulative effects of regulations; Support extension of comment deadline for Federal Reserve proposal on decreasing the debit interchange fee cap (Docket No. R‐1818); Support extension of comment deadline for CFPB proposal on personal financial data rights (Docket No. CFPB-2023-0052); Support CFPB transparency on its use of artificial intelligence technology; Support NCUA transparency on initiatives to support financial technology innovation; Support NCUA creating a regulatory sandbox to support financial technology innovation; Support a delay in the effective date for the CFPBs Section 1071 final rule for all covered entities; Support NCUA raising commercial loan threshold to $250,000 from current level of $50,000; Support CFPB convening SBREFA panels for credit card late fee rulemaking; Oppose Regulation E liability for financial institutions for consumer-authorized transactions; Support FHFA reopening seasoned bulk transactions window.

Protect the credit union tax exemption; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their nearly 140 million members; Support regulatory relief for credit unions; Provide guidance or rulemakings rather than rule through enforcement; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; Support increase in funding for CDFI Fund, MDIs, and the CDRLF; Support extending GLBA-like data security measures to retailers and fintechs; Support recognizing GLBA compliance in any privacy legislation; Oppose private right of action in data privacy legislation; Support NCUA as credit unions sole data privacy regulator; Oppose opt-in requirement for use of non-public personal information in data privacy legislation; Support federal preemption of state data privacy laws; Oppose NCUA examination authority for 3rd party vendors; Oppose NCUA adopting a dedicated consumer compliance examination; Support extended NCUA examination cycle; Support NCUA Central Liquidity Facility (CLF) improvements; Support vendor information sharing among financial regulators; Support NCUA independence as regulator and insurer; Oppose unsustainable NCUA budget growth; Support increased NCUA assistance for MDI credit unions; Support adjusting Dodd-Frank Act thresholds for inflation; Support legislative action to limit Regulation E liability; Support fair distribution of Regulation E error resolution responsibilities; Support greater investment authorities for credit unions; Support expansion of Low-Income Housing Tax Credit; Support publication of list of entities with access to Federal Reserve Bank accounts and services; Support legislative action to clarify CFPBs UDAAP authority; Support parity in credit union and bank federal deposit insurance levels; Oppose increased NCUA authority to charge share insurance premiums; Oppose SBA direct lending authority; Oppose fintech participation in SBA lending programs; Prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; Support increased CFPB transparency in rulemaking, supervision, and enforcement; Support CFPB coordination with NCUA in policymaking; Support CFPB basing policy on thorough research and data analysis; CFPB should engage in interagency coordination on Section 1033 consumer access to financial records rulemaking; Oppose CFPBs characterization of regulated and disclosed financial services fees as junk fees; CFPB should explore streamlining required fee disclosures; Oppose mandatory grace period for credit card late payments; CFPB should clarify UDAAP authority; CFPB should respect GLBAs data security regulatory structure; CFPB should limit impact and burden from final rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); Support prohibiting CFPB expending funds to implement the Section 1071 Small Business Lending Data Collection final rule (RIN: 3170-AA09); Improve examination coordination between CFPB and NCUA; Support CFPB exercise of larger participant authority to oversee fintech companies; Support clear regulatory framework for digital assets to encourage responsible innovation and permit credit union participation; Support CDFI Fund transparency on certification changes; Oppose changes to CDFI Fund certification process; Support Congressional oversight of SBAs Affiliation and Small Business Lending Company final rules; Support legislation to limit impact of SBAs Affiliation and Small Business Lending Company final rules; Support tax deduction for mortgage insurance premiums; Support modification or removal of the credit union member business lending cap; Support increasing credit union loan maturity limits; Support allowing credit unions to add underserved areas to their FOM; Support removing service area requirement for FOM expansion; Support increasing the credit union interest rate ceiling; Oppose national all-in interest rate cap; Oppose expanding the Fair Debt Collection Practices Act to cover business loans; Support credit union Community Reinvestment Act exemption; Support regulator-approved credit union mergers; Support regulations adhering to intent of the Fair Credit Reporting Act; Support regulation of credit reporting agencies and credit repair organizations; Oppose legislation granting for-profit banks nominal leases on military installations; Support credit union access to nominal leases on military installations; Support alternative credit scoring models; Oppose exclusion of accurate information from credit reports; Support FinCEN funding; Support FinCEN oversight; Support increasing SAR and CTR thresholds; Support disbursal of ECIP funding; Oppose NCUA acting as a climate regulator; Support credit union eligibility for the Greenhouse Gas Reduction Fund; Support Congressional oversight of the Federal Reserve Overnight Reverse Repo Facility; FCC should tailor robocall and robotext regulations to allow credit unions to serve their members; Support placing CFPB under regular appropriations process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs and consider wealth-building home loan pilot programs; Oppose increase in FHFA guarantee fees; Support elimination of guarantee fees for credit union mortgages; Support regulation of fintechs in mortgage lending; Support alternative credit scoring models; Oppose development of a CBDC; Support prevention of an NFIP lapse; Support improving veterans access to capital by exempting credit unions business loans to veterans from the credit union member business lending cap; Support expanding the definition of Community Financial Institutions (CFIs) in the Federal Home Loan Bank Act (FHLB Act) to include credit unions and Treasury-certified non-depository community development financial institutions; Support government guarantees to stabilize mortgage-backed securities market; Support pilot programs for wealth-building home loans and zero-down mortgages; Support quality- rather than quantity-based GSE loan pricing; Oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; Support parity for credit unions related to stablecoin regulation; Treasury should address the demand for coins to help consumers who rely on cash transactions; Support addressing appraisal bias and modernize the appraisal process for consistency; Support easing requirements for de novo credit unions; Support providing flexibility for credit unions to issue subordinated debt; Support improvements to ease the process for forgiveness of PPP loans to small businesses; Oppose limits on fee income for credit unions including courtesy pay; Support limiting burdens of HMDA rule on credit unions; CFPB should remove unnecessary and unused data points related to HMDA reporting; Support permanently increasing reporting thresholds for open- and closed-end loans; Support permanent adoption of CFPBs expired temporary relief of E-SIGN regulation; Oppose Federal Reserve proposal to decrease debit interchange fee cap (Docket No. R‐1818); Support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support Credit Union Board Modernization Act (H.R. 582; S. 610); Support Promoting Access to Capital in Underbanked Communities Act (H.R. 758); Support Promoting New and Diverse Depository Institutions Act (H.R. 1533; S. 2252); Support Consumer Financial Protection Commission Act (H.R. 1410); Support SECURE Notarization Act (H.R. 1059; S. 1212); Support Prohibiting IRS Financial Surveillance Act (H.R. 1010; S. 453); Support CBDC Anti-Surveillance State Act (H.R. 1122; H.R. 5403); Support Data Privacy Act (H.R. 1165); Support Veterans Member Business Loan Act (S. 539; H.R. 4867); Support NCUA Central Liquidity Facility Enhancements (S. 544); Support Neighborhood Homes Investment Act (S. 657); Support CDFI Bond Guarantee Program Improvement Act (S. 869); Support Small LENDER Act (H.R. 1806); Support Transparency in CFPB Cost-Benefit Analysis Act (H.R. 1313); Support Making the CFPB Accountable to Small Businesses Act (H.R. 1749); Support Resolution of Disapproval of the CFPBs Section 1071 final rule (H.J.Res. 50; H.J.Res. 66; H.J.Res. 85; S.J.Res. 32) Support CFPB Transparency and Accountability Reform Act (H.R. 2798); Support SAFE Banking Act (H.R. 2891; S. 1323); Support CDFI Fund Transparency Act (H.R. 3161; S. 2674); Support Building Credit Access for Veterans Act (H.R. 1266); Support Increasing Financial Regulatory Accountability and Transparency Act (H.R. 3556); Support Middle Class Borrower Protection Act (H.R. 3564; S. 2296); Support Digital Dollar Pilot Prevention Act (H.R. 3712); Oppose Credit Card Competition Act (H.R. 3881; S. 1838); Support Member Business Loan Expansion Act (H.R. 4868); Oppose Senate NDAA amendments on interchange (#177; #425); Support Clarity for Payment Stablecoins Act (H.R. 4766); Support Senate NDAA amendment on financial literacy (#206); Support Homes for Every Local Protector, Educator, and Responder (HELPER) Act (H.R. 3170; S. 1514); Oppose Senate appropriations amendment on interchange (#1161); Oppose Senate appropriations amendments on interest rate caps (#1225; #1285); Oppose Capping Credit Card Interest Rates Act (S. 2760); Support SAFER Banking Act (S. 2860); Oppose Amendment #117 to H.R. 4664; Support Amendment #174 to H.R. 4664; Support provisions of H.R. 4664 to place CFPB under the regular appropriations process and restructure the Bureau to a bipartisan commission; Support Rectifying UDAAP Act (H.R. 6789); Support Close the Shadow Banking Loophole Act (S. 3538); Oppose Predatory Lending Elimination Act (S. 3549); Comments to NCUA on OMB Number: 3133-NEW supporting streamlined speaker request forms and increased transparency in speaker request process; Comments to Office of the National Cyber Director on RIN: 0301-AA00 supporting regulatory harmonization and minimizing overlapping or conflicting requirements; Comments to CFPB on Outline of FCRA Proposals supporting adherence to Congressional intent and reissuance of proposals with more detail and specificity; Comments to Department of Labor on RIN 1235-AA39 opposing automatic adjustments and encouraging accommodation of smaller credit unions; Comments to NCUA on proposed 2024-2025 budget opposing unsustainable budget increases and encouraging cost-savings and transparency; Comments to OMB on OMB-2023-0020 supporting increased transparency on agencies use of artificial intelligence technology; Comments to NCUA on Docket No. NCUA-2023-0082 supporting simplification of share insurance for trust accounts; Comments to CFPB on Docket No. CFPB-2023-0052 opposing the proposal and urging CFPB to reduce burden on credit unions and adopt a safe harbor for data providers; Support FHFA publishing data and analysis related to credit score model validation; Support regulatory cost-benefit analysis that includes cumulative effects of regulations; Support extension of comment deadline for Federal Reserve proposal on decreasing the debit interchange fee cap (Docket No. R‐1818); Support extension of comment deadline for CFPB proposal on personal financial data rights (Docket No. CFPB-2023-0052); Support CFPB transparency on its use of artificial intelligence technology; Support NCUA transparency on initiatives to support financial technology innovation; Support NCUA creating a regulatory sandbox to support financial technology innovation; Support a delay in the effective date for the CFPBs Section 1071 final rule for all covered entities; Support NCUA raising commercial loan threshold to $250,000 from current level of $50,000; Support CFPB convening SBREFA panels for credit card late fee rulemaking; Oppose Regulation E liability for financial institutions for consumer-authorized transactions; Support FHFA reopening seasoned bulk transactions window.

All legislation related to consumer lending regulation and consumer lending policy. S. 1323, The SAFE Banking Act of 2023 H.R. 2891, The SAFE Banking Act of 2023 S, 293, The Fair Access to Banking Act H.R. 2743, The Fair Access to Banking Act S. 2860, The SAFER Banking Act S. 2730, The Protecting Consumers from Unreasonable Credit Rates Act of 2023 S. 3549, The Predatory Lending Elimination Act

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Bank On Central Bank Digital Currency Cryptocurrency Deposit Insurance Digital Assets Nominations Bank Capital Requirements/Basel Capital Proposal Postal Banking S.1323 & H.R.2891, Secure and Fair Enforcement (SAFE) Banking Act of 2023 H.R. 4177 & S. 2007, Improving Corporate Governance Through Diversity Act of 2023 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 758, Promoting Access to Capital in Underbanked Communities Act of 2023 H.R.4590, Promoting New and Diverse Depository Institutions Act H.R. 1533, Promoting New and Diverse Depository Institutions Act Emergency Capital Investment Issues for CDFI and MDI H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. H.R. 7003, Expanding Financial Access for Underserved Communities Act S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on Banking. UDAAP Supervisory Policies and Adjudication Procedures Community Reinvestment Act modernization Deposit Insurance Assessment Rates S.1838, Credit Card Competition Act of 2023 H.R. 3881, Credit Card Competition Act of 2023 S.4760, Digital Commodities Consumer Protection Act of 2022 Merchant Category Codes S.1790, Failed Bank Executives Clawback Act S.293 & H.R. 2743, Fair Access to Banking Act H.R. 2799, Expanding Access to Capital Act of 2023 H.R. 2603, To require the Securities and Exchange Commission to revise certain thresholds related to smaller reporting companies, accelerated filers, and large accelerated filers, and for other purposes H.R. 2798, Consumer Financial Protection Bureau Transparency and Accountability Reform Act H.R. 1382, TABS Act of 2023 H.R. 1411, Consumer Financial Protection Bureau-Inspector General Reform Act H.R. 2489, the Consumer Financial Protection Bureau Dual Mandate and Economic Analysis Act H.R. 1313, the Transparency in Consumer Financial Protection Bureau Cost-Benefit Analysis Act H.R. 1719, Making the Consumer Financial Protection Bureau Accountable to Small Business Act S.1362, the Transparency in Consumer Financial Protection Bureau Cost-Benefit Analysis Act H.R. 490, Federal Infrastructure Bank Act of 2023 H.R. 4868, Member Business Loan Expansion Act H.R. 4035, Protecting Small Business Information Act of 2023 S.2760, Capping Credit Card Interest Rates Act H.R. 5485, Financial privacy Act of 2023 H.R. 5524, Foreign Affiliate Sharing Pilot Program H.R. 5403, Central Bank Digital Currency Anti-Surveillance Act H.R. 5741, Uniform Treatment of Custodial Assets Act S. 2860, Secure and Fair Enforcement Regulation (SAFER) Banking Act H.R. 4763, Financial Innovation and Technology for the 21st Century Act H.R. 4766, Clarity for Payment Stablecoins Act of 2023 S. 2190, Recovering Executive Compensation Obtained Through Unaccountable Practices (RECOUP) Act of 2023 S. 2251, Federal Information Security Modernization Act H.R. 3398, Safe Access to Cash Act of 2023 S. 3549, the Predatory Lending Elimination Act H.R. 6789, Rectifying UDAAP Act H.R. 1810, Bank Loan Privacy Act H.R. 1806/S. 1159, Small Lender Act H.R. 4346, Small Bank Holding Company Relief Act of 2023 H.R. 4198, Protecting Consumers from Abusive Mortgage Leads Act S. 3502, Homebuyers Privacy Protection Act Regulation II: Debit Card Interchange Fees and Routing Implementation of Dodd-Frank Act Section 1033-- Proposed Rule on Personal Financial Data Rights Department of Labor Retirement Security Rule: Definition of an Investment Advice Fiduciary (Fiduciary Rule) S.3554, Financial Artificial Intelligence Risk Reduction Act CDFI Certification Update

H.R. 758 Promoting Access to Capital in Underbanked Communities Act of 2023 H.R. 1122 Central Bank Digital Currency Anti-Surveillance State Act H.R. 1165 Financial Data Privacy Act of 2023 H.R. 1313 Transparency in CFPB Cost-Benefit Analysis Act H.R. 1749 Making the CFPB Accountable to Small Business Act H.R. 1806 Small LENDER Act H.R. 1810 Bank Loan Privacy Act H.R. 2656 Trigger Leads Abatement Act H.R. 2670, National Defense Authorization Act for Fiscal Year 2024 Digital Assets Regulation H.R. 2670, National Defense Authorization Act for Fiscal Year 2024, Amendments 425, 177 & S.1838: Durbin Amendment on Debit Card Routing; Extension to Credit Cards H.R. 2798 CFPB Transparency and Accountability Reform Act H.R. 2891 SAFER Banking Act of 2023 H.R. 3881 Credit Card Competition Act of 2023 H.R. 4035, Protecting Small Business Information Act of 2023 H.R. 4198 To amend section 604(c) of the Fair Credit Reporting Act to address the treatment of pre-screening report requests, and for other purposes. H.R. 4673 Financial Innovation and Technology for the 21st Century Act 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.J. Res. 50 A Resolution of Disapproval under the Congressional Review Act Re: Dodd-Frank Section 1071 H.J. Res. 66 A Resolution of Disapproval under the Congressional Review Act Re: Dodd-Frank Section 1071 S. 1045 Bank Compensation Clawback S. 1323 SAFE Banking Act of 2023 S. 1838 Credit Card Competition Act of 2023 S. 2190 RECOUP Act S. 2281 Lummis-Gillibrand Responsible Financial Innovation Act S. 2669 Digital Asset Anti-Money Laundering Act of 2023 S. 2760, the Capping Credit Card Interest Rates Act S. 2860 SAFER Banking Act S. 3012 Deposit Security Act S. 3502 Homeowners Privacy Protection Act (Trigger Leads) S. 3538 Close the Shadow Banking Loophole Act S. 3541 FAIR Exams Act S. 3549 The Predatory Lending Elimination Act Senate Amendment 1161 to H.R. 4366 - Military Construction, Veterans Affairs, and Related Agencies Appropriations Act, 2024 - Credit Card Competition Act S.J. Res. 32 A Resolution of Disapproval under the Congressional Review Act Re: Dodd-Frank Section 1071 Anti-money laundering regulation - digital assets Beneficial Ownership Cannabis Banking Central Bank Digital Currency Check Fraud Climate Risk Disclosure Requirements Climate Related Financial Regulation 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 Crypto Assets, Decentralized Finance, and Central Bank Digital Currency Cryptocurrency Regulation Data privacy De Novo Bank Formation Debit Card Interchange Fees and Routing Deposit insurance reform Digital Assets Regulation Dodd Frank Act 1071- Small Business Loan Data Collection Durbin Amendment on Debit Card Routing; Extension to Credit Cards FDIC Deposit Insurance Assessments FDIC Deposit Insurance Policy Federal Reserve Master Accounts 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 Interest rate caps Legality Special Purpose Credit Programs 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 Special Purpose Credit Programs (SPCPs) Stablecoin, Crypto Currency Regulatory Policy Stablecoins

LEGISLATIVE House H.R. 2798- CFPB Transparency and Accountability Reform Act H.R. 1410- Consumer Financial Protection Commission Act H.R. 1382- TABS Act of 2023 H.R. 1313- Transparency in CFPB Cost-Benefit Analysis Act H.R. 1411- CFPB-IG Reform Act of 2023 H.R. 1165- Data Privacy Act of 2023 H.R. 3881- Credit Card Competition Act of 2023 H.R. 4766- Clarity for Payment Stablecoins Act Legislation related to the Small Business Administration 7(a) loan program Legislation related to small dollar lending Issues related to implementation of Section 1071 of the Dodd-Frank Act H.R. 2670- National Defense Authorization Act for Fiscal Year 2024 H.R. 4277- Overdraft Protection Act of 2021 (117th Cong.) H.R. 6789- Rectifying UDAAP Act Senate S. 1362- Transparency in CFPB Cost-Benefit Analysis Act S. 1838- Credit Card Competition Act of 2023 S. 2760- Capping Credit Card Interest Rates Act S. 3549- Predatory Lending Elimination Act S. 2482- Community Advantage Loan Program Act Both Chambers Issues related to Zelle payment platform and changes to Regulation E Issues related to Biden Administration Student Loan Forgiveness Plan Issues related to banning arbitration agreements House/Senate Semi-annual Hearing with the Director of the CFPB Issues related to Financial Services and General Government Appropriations Issues related to Consumer Data Privacy Legislation related to establishing a commission at the CFPB Issues related to disclosures for federal student loans Legislation related to student loan refinancing programs Issues related to bankruptcy protections for student loans Issues related to federal student loan reform Issues related to Cyber Security, Data Security & Breach Notification Issues related to credit card network interchange fees Issues related to financial regulatory coordination Issues related to the Paperwork Reduction Act Issues related to the Higher Education Act Issues related to fraud and scams REGULATORY Privacy Issues, 12 CFR Parts 40, 216, 332, 1016 CFPB Issues related to Section 1033 of Dodd-Frank Issues related to CFPB Credit Card late fees Safe Harbor rule Issues related to UDAAP exam manual changes Issues related to Section 1071 Small Business Data Collection Issues related to Overdraft and non-sufficient funds (NSF) fees Issues related to Fintech oversight Issues related to Section 1034 of Dodd-Frank Act Issues related to the Fair Credit Reporting Act Issues related to CFPB supervisory authority under Section 1024 Issues related to CFPB agency guidance Issues related to CFPB Consumer Response Portal Issues related to CFPB Taskforce on Consumer Financial Laws Issues related to the Servicemembers Civil Relief Act Issues related to the Military Lending Act Issues related to Electronic Fund Transfer Act, regulation E, 15 U.S.C. 1693 Equal Credit Opportunity issues, Regulation B, 12 CFR Part 1002 Home Mortgage Disclosure Act Issues, Regulation C, 12 CFR Part 1003 Fair Credit Reporting Issues, 12 CFR Parts 41, 171, 334, 1022 Truth in Lending Issues, Regulation Z, 12 CFR Part 1026 Fair Debt Collection Practices Issues, Regulation F, 12 CFR Part 1006 OCC Issues related to the Community Reinvestment Act Issues related to fair lending and fair banking Issues related to the Fair Housing Act Issues related to Underbanked/Unbanked Consumers- Consumer Financial Health Federal Reserve Issues related to the Federal Reserve Central Digital Bank Currency Issues related to the Federal Reserve Consumer checking accounts Issues related to the Community Reinvestment Act Issues related to Basel III Endgame Proposal FDIC Issues related to FDIC Deposit Insurance Issues related to the Bank Secrecy Act and Anti-Money Laundering Issues related to the Counter Terrorism & Illicit Finance Act Issues related to Parent Companies of Industrial Banks and Industrial Loan Companies Issues related to the Community Reinvestment Act Issues related to Section 19 - Criminal Background for prospective employment SBA Issues related to Small Business Act Issues related to SBA 7(a) Loan Program and fees Issues related to SBA 504 Loan Program and fees Department of Education Issues related to the CFPBs and Department of Educations actions on student lending

Legislative proposals impacting banking services for financial services providers; Payday, Vehicle Title, and Certain High-Cost Installment Loans; Federal policy relating to anticipated Consumer Financial Protection Bureau regulation of consumer financial services including payday and auto title lending, and regulatory process; H.R.1382, TABS Act of 2023; H.R.1165, Data Privacy Act of 2023; H.R.2798, CFPB Transparency and Accountability Reform Act; S.3549, Predatory Lending Elimination Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE