Secure Payments Act of 2024

H.R. 3881, S.1838, H.R. 7531, H.R. 8818, S. 4570, S. 2730, S. 3549, S. 2760 - Discussed consumer protection, digital identification, credit reporting, and privacy issues related to financial services and products. Discussed issues related to credit and debit card services.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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

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

S. 1838 / H.R. 3881 Credit Card Competition Act of 2023, issues related to swipe fees and competitive routing. S.4570 / H.R. 7531, Secure Payments Act. H.R. 8337, Bank Resilience & Regulatory Improvement Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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

Data privacy issues and legislative proposals. H.R. 3881/S. 1838, Credit Card Competition Act of 2023. S. 1419, Kids Online Safety Act. S. 1418, Children and Teens' Online Privacy Protection Act. FTC Notice of Proposed Rulemaking: Non-Compete Clause Rule. FTC Notice of Proposed Rulemaking: Trade Regulation Rule on Unfair or Deceptive Fees. Federal Reserve System Notice of Proposed Rulemaking: Debit Card Interchange Fees and Routing. S. 3161, Promoting Real-time Information on Cost Expenditure (PRICE) Act. H.R. 7531/S. 4570, Secure Payments Act of 2024. H.R. 7520, Protecting Americans' Data from Foreign Adversaries Act 2024. S. 4195, Childhood Diabetes Reduction Act of 2024. H.R. 8818, American Privacy Rights Act of 2024. H.R. 8337, Bank Resilience and Regulatory Improvement Act.

Client expense: $820,000 · Firm income: Not reported

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

H.R. 3881, S.1838, H.J. Res. 122, H.J. Res. 121, H.R. 7531, H.R. 8818, S. 4570, S.J. Res. 70 - Discussed consumer protection, digital identification, credit reporting, and privacy issues related to financial services and products. Discussed issues related to credit and debit card services.

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

Issues related to the retail payments market, swipe fee reform, the Credit Card Competition Act - S. 1838/H.R. 3881 Regulation II - debit routing and debit regulated rate Issues related to coin circulation Secure Payments Act - H.R. 7531/S. 4570 Issues related to debit asset threshold, H.R. 6398/H.R. 8337

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

Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE

Issues related to interchange fees and creating competition in payment markets. H.R.3881/S.1838 - Credit Card Competition Act of 2023. H.R.7531- Secure Payments Act. Issues related to debit card fee rate setting by the Federal Reserve. S.4570 - Secure Payments Act of 2024.

Client expense: Not reported · Firm income: $90,000

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

S. 1838 / H.R. 3881 Credit Card Competition Act of 2023, issues related to swipe fees and competitive routing. S.4570 / H.R. 7531, Secure Payments Act. H.R. 8337, Bank Resilience & Regulatory Improvement Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Discussions in support of the Credit Card Competition Act of 2023 (H.R.3881/S.1838) Discussions opposing efforts to postpone Federal Reserve rulemaking, S.4570/H.R.7531, Secure Payments Act

Client expense: $1,490,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to the retail payments market, swipe fee reform, the Credit Card Competition Act - S. 1838/H.R. 3881 Regulation II - debit routing and debit regulated rate Issues related to coin circulation Secure Payments Act - H.R. 7531/S. 4570 Issues related to debit asset threshold, H.R. 6398/H.R. 8337 FAA reauthorization amendments, H.R. 3935

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

Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE

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

H.R. 3881, S.1838, H.J. Res. 122, H.J. Res. 121, H.R. 7531, H.R. 8818, S. 4570, S.J. Res. 70 - Discussed consumer protection, digital identification, credit reporting, and privacy issues related to financial services and products. Discussed issues related to credit and debit card services.

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

S. 1838 / H.R. 3881, Credit Card Competition Act. Issues related to competitive routing. Issues related to Reg II. S.4570 / H.R. 7531 Secure Payments Act. H.R. 8337, Bank Resilience and Regulatory Improvement Act.

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

Government targets: 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

S. 1838 / H.R. 3881 Credit Card Competition Act of 2023, issues related to swipe fees and competitive routing. S.4570 / H.R. 7531, Secure Payments Act. H.R. 8337, Bank Resilience & Regulatory Improvement Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE