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A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of Currency relating to "National Banks and Federal Savings Associations as Lenders".
Legislative Progress
Momentum (last 30 days)
0
score
0 actions · 0 new cosponsors · 0 votes
Speed vs cohort
93pct
97d open
vs 70 other SJRES bills in the 117th — cohort avg 22d
This joint resolution nullifies the final rule issued by the Office of the Comptroller of the Currency titled National Banks and Federal Savings Associations as Lenders and published on October 30, 2020. The rule requires that to be considered a lender, a national bank or federal saving association must, as of the date of origination of the loan (1) be named as the lender in the loan agreement, or (2) fund the loan.
Yes
270
No
255
Present
0
Not Voting
5
Party Breakdown
These links require the bill number to appear in the filing's source-reported specific issue text. Client expenses and lobbying-firm income are separate disclosure fields.
Became Public Law No: 117-24.
Became Public Law No: 117-24.
Signed by President.
Signed by President.
Presented to President.
Presented to President.
Motion to reconsider laid on the table Agreed to without objection.
On passage Passed by the Yeas and Nays: 218 - 208 (Roll no. 181). (text: CR H3100)
HousePassed/agreed to in House: On passage Passed by the Yeas and Nays: 218 - 208 (Roll no. 181).(text: CR H3100)
HouseConsidered as unfinished business. (consideration: CR H3114)
POSTPONED PROCEEDINGS - At the conclusion of debate on S.J.Res 15, the Chair put the question on passage of the bill and by voice vote, announced that the ayes had prevailed. Mr. McHenry demanded the yeas and nays and the Chair postponed further proceedings on passage of the bill until a time to be announced.
Bills with similar content found using semantic analysis.
Sources: Congress.gov · House Clerk roll-call votes
| #181 | house | On Passage | Passed | June 24, 2021 |
| #183 | senate | On the Joint Resolution | Joint Resolution Passed (52-47) | May 11, 2021 |
2026 · third_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, Corporate Transparency Act, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations, securitization surcharge/p-factor). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $325,946 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2026 · second_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, Corporate Transparency Act, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations, securitization surcharge/p-factor). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
2026 · first_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, Corporate Transparency Act, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations, securitization surcharge/p-factor). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
2025 · fourth_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, Corporate Transparency Act, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations, securitization surcharge/p-factor). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
2025 · third_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, Corporate Transparency Act, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations, securitization surcharge/p-factor). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
The previous question was ordered pursuant to the rule.
DEBATE - The House proceeded with one hour of debate on S.J. Res. 15.
The resolution provides for 1 hour of debate, orders the previous question, and allows a motion to recommit for each measure. Provides that H. Res. 485 is adopted. Provides that anytime through the legislative day of June 25, 2021, the Speaker may entertain motions offered by the Majority Leader or his designee that the House suspend the rules with respect to multiple measures that were the object of motions to suspend the rules on the legislative days of June 22 or 23, and on which the yeas and nays were ordered and further proceedings postponed.
Considered under the provisions of rule H. Res. 486. (consideration: CR H3099-3110)
Rule H. Res. 486 passed House.
Rules Committee Resolution H. Res. 486 Reported to House. The resolution provides for 1 hour of debate, orders the previous question, and allows a motion to recommit for each measure. Provides that H. Res. 485 is adopted. Provides that anytime through the legislative day of June 25, 2021, the Speaker may entertain motions offered by the Majority Leader or his designee that the House suspend the rules with respect to multiple measures that were the object of motions to suspend the rules on the legislative days of June 22 or 23, and on which the yeas and nays were ordered and further proceedings postponed.
Held at the desk.
Received in the House.
Message on Senate action sent to the House.
Passed Senate without amendment by Yea-Nay Vote. 52 - 47. Record Vote Number: 183. (text: CR S2441)
SenatePassed/agreed to in Senate: Passed Senate without amendment by Yea-Nay Vote. 52 - 47. Record Vote Number: 183.(text: CR S2441)
SenateMeasure laid before Senate by motion. (consideration: CR S2430-2431, S2436-2441)
Motion to proceed to consideration of measure agreed to in Senate by Voice Vote.
Placed on Senate Legislative Calendar under General Orders. Calendar No. 57.
Senate Committee on Banking, Housing, and Urban Affairs discharged by petition pursuant to 5 U.S.C. 802(c).
Senate Committee on Banking, Housing, and Urban Affairs discharged by petition pursuant to 5 U.S.C. 802(c).
Committee on Banking, Housing, and Urban Affairs. Hearings held.
Read twice and referred to the Committee on Banking, Housing, and Urban Affairs.
Introduced in Senate
| March 25, 2021 |
| Enrolled Bill | -- |
| Democratic |
| RI |
| Jeff Merkley | Democratic | OR |
| Richard J. Durbin | Democratic | IL |
| Sheldon Whitehouse | Democratic | RI |
| Sherrod Brown | Democratic | OH |
| Tina Smith | Democratic | MN |
Client expense: $309,861 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
Client expense: $387,651 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
Client expense: $353,844 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
Client expense: $347,609 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2025 · second_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, Corporate Transparency Act, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations, securitization surcharge/p-factor). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $314,666 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2025 · first_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, Corporate Transparency Act, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations, securitization surcharge/p-factor). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $338,881 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2024 · fourth_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, Corporate Transparency Act, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations, securitization surcharge/p-factor). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $242,716 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2024 · third_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations, securitization surcharge/p-factor). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $253,750 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2024 · second_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations, securitization surcharge/p-factor). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $256,928 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2024 · first_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations, securitization surcharge/p-factor). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $258,149 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2023 · fourth_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $267,129 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2023 · third_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $239,692 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2023 · second_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $203,106 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2023 · first_quarter · Banking
Bank On Buy Now, Pay Later Central Bank Digital Currency Cryptocurrency Digital Assets Nominations USPS Pilot Banking Program H.R. 1996, The SAFE Banking Act H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 758, Promoting Access to Capital in Underbanked Communities Act of 2023 S. 910, SAFE Banking Act S.J.RES.15, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of Currency relating to "National Banks and Federal Savings Associations as Lenders." H.R.1533, Promoting New and Diverse Depository Institutions Act H.R. 6145, Community Bank Relief Act of 2021 S. 3409, To amend the Economic Growth, Regulatory Relief, and Consumer Protection Act to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024. Emergency Capital Investment Issues for CDFI and MDI S. 3715, The E-SIGN Modernization Act Coin Circulation H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. H.R. 4277, Overdraft Protection Act of 2021 H.R 4521, America Competes Act of 2022 H.R.7003, Expanding Financial Access for Underserved Communities Act S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on Banking. UDAAP Supervisory Policies and Adjudication Procedures Issues impacting the modernization of the Community Reinvestment Act Deposit Insurance Assessment Rates S.4674, Credit Card Competition Act H.R. 8874, Credit Card Competition Act S.4760, Digital Commodities Consumer Protection Act of 2022 Merchant Category Codes
Client expense: $1,830,000 · Firm income: Not reported
Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2023 · first_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.
Client expense: $156,053 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2022 · fourth_quarter · Banking
1) Maintain Stop Biased Banking website. No specific legislation. 2) Repeal Foreign Account Tax Compliance Act. No specific legislation. 3) Oppose Federal Reserve establishing a real-time payment system - 83 FR 57351 4) Oppose expansion of Dodd-Franks Durbin Amendment to credit cards. No specific legislation. 5) Oppose overturning the True Lender rule - S.J. Res. 15. 6) Oppose SEC proposal interfering in private partnership agreements between investors and private fund advisers. [Release Nos. IA-5955; File No. S7-03-22]
Client expense: Not reported · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of
2022 · fourth_quarter · Financial Institutions/Investments/Securities
Federal policy relating to anticipated Consumer Financial Protection Bureau regulation of consumer financial services including payday lending, auto title lending, and regulatory process. Potential legislation to regulate interest rates on financial products. S.J. Res. 15 - A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders." Implementation of the CARES Act (PL 116-136), provisions relating to the payroll protection program. Implementation of the American Rescue Plan Act of 2021 (PL-117-2), provisions relating to the payroll protection program. Legislative proposals relating to prohibiting retail businesses from refusing cash payments. H.R. 2040, The Financial Reporting Threshold Modernization Act, provisions relating to updating thresholds for certain currency transaction reports and suspicious activity reports. H.R. 1996, The SAFE Banking Act of 2021, provisions relating to the provision of financial services to cannabis-related businesses and service providers S. 563, The Fair Access to Banking Act, provisions relating to fair access to financial services and discount window lending programs. Veterans and Consumers Fair Credit Act (H.R. 5974/S. 2508), provisions relating to regulation of interest rates on financial products.
Client expense: Not reported · Firm income: $50,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2022 · fourth_quarter · Banking
Issues related to Federal Credit Union Charter Modernization Issues related to credit union operations Issues related to credit union field of membership Issues related to credit union service organization Issues related to NCUA's low income designation regulation Issues related to NCUA examination procedures Issues related to NCUA's regulation regarding liquidity Issues related to NCUA's rulemaking process Issues related to NCUA's regulatory review process Issues related to Federal Credit Union Bylaws Issues related to credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union By-Laws Issues related to credit unions' incidental powers Issues related to credit union service to marijuana businesses Issues related to material loss reports of the NCUA Office of Inspector General Issues related to the regulation of corporate credit unions Issues related to fixed assets Issues related to credit union conversions Issues related to credit union call report modernization Issues related to NCUA's Corporate Credit Union Stabilization Plan Issues related to NCUA's budget and the overhead transfer rate Issues related to Credit Union Service Organizations (CUSO) Issues related to the authority of the CFPB to exempt credit unions from its rulemaking Issues related to the CFPB rule to remittances and international wire transfers Issues related to CFPB's Leadership structure and Installing a Board rather than a Director Issues related to codifying the CFPB's Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to overdraft protection and check ordering practices Issues related to mortgage servicing Issues related to mortgage loan originator compensation and qualifications Issues related to the CFPB's rule regarding qualified mortgage / ability to repay Issues related to the CFPB's regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the CFPB's regulation on Truth-In-Lending Act / Real Estate Settlement Procedures Act Integrated Disclosures Issues related to the payday, vehicle title, and similar lending Issues related to short term lending products and advance deposit products Issues related to the CFPB's consumer complaint database Issues related to the CFPB's consumer complaint database Issues related to the Department of Justice's investigation entitled, "Operation Choke Point" Issues related to indirect auto lending Issues related to credit union service to unbanked and underbanked consumers Issues related to the Financial Accounting Standards Board (FASB) Issues related to data and cyber security Issues related to mobile banking and mobile payments Issues related to identity theft and fraud reduction Issues related to secure payments Issues related to merchant data breaches Issues related to the payments system and innovation Issues related to the Fed's implementation of same-day ACH Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements Issues related to the oversight of the Federal Housing Administration Issues related to the USDA Rural Development Loan Program Issues related to the Federal Home Loan Bank System Issues related to membership eligibility in the Federal Home Loan Bank System Issues related to financial literacy Issues related to Housing Finance Reform Issues related to student lending Issues related to the Economic Growth and Regulatory Paperwork Reduction Act Process Issues related to retirement security Issues related to flood insurance Issues related to consumer's access to records Issues related to Interchange Fees Issues related to the Equal Credit Opportunity Act Issues related to the Fair Housing Act Issues related to the merger of credit unions Issues related to the Real Estate Settlement Procedures Act Issues related to Community Reinvestment Act Issues related to Regulation Z Issues related to Military Lending Act Issues related to Financial Technology Issues related to Small Business Lending Data Collection requirements Issues related to Involuntary liquidation of Federal Credit Unions and Claims Procedures Issues related to Web-Bases Quantitative Testing of Point of Sale / ATM Overdraft Disclosure Forms Issues related to residential appraisals Issues related to FHA appraisal certification Issues related to FHA and USDA Loan Modifications Issues related to Faster Payments Issues related to the Fair Credit Reporting Act Issues related to cooperative funding sources in federal appropriations legislation Issues related to regulation of debt collection activity Issues related to capital reform for credit unions Issues related to diversity and inclusion in Financial Services Issues related to Section 124 of the Federal Credit Union Act Issues related to the Consumer Financial Protection Bureau's No-Action Letters and the BCFP Product Sandbox Issues related to enterprise validation and approval of credit score models Issues related to the availability of Funds and Collection of Checks (Regulation CC) Issues related to arbitration clauses Issues related to SBA 7(a) loan program Issues related to financial institutions operating on military installations Issues related to postal banking Issues related to Telephone Consumer Protection Act Issues related to financial technology (FINTECH) Issues related to robocalls and the draft Declatory Ruling (the ruling) and Third Further Notice of Proposted Rulemaking (FNPRM) CG Docket No 17-59, WC Docket No. 17 - 97 Issues related to payday and small dollar lending Issues related to leases of non-excess property on military bases Issues related to Opportunity Zones Issues related to minority homeownership Issues related to the ability of Federal Credit unions to establish their own fiscal year Issues related to a requirement that Federal credit unions file certain information regarding loan officers Issues related to enhancing flexibility of Federal Credit Unions to schedule board meetings Issues related to removing certain outdated responsibilites of Federal credit union board of directors Issues related to permitting Federal credit unions to expel disruptive members for just cause without a vote Issues related to permitting balloting for conversions from state to federal charter and from federal to state charter to be conducted electronically Issues related to PACE Loans Issues related to minority depository insitutions Issues related to AI and cloud computing Issues related to the Consumer Online Privacy Rights Act Issues related to COVID-19 crisis response legislation Issues related to the Paycheck Protection Program Issues related to Taxi Medallion loans Issues related to QRM Risk Retection Review Issues related to NCUA's proposed rule on combination transactions Issues related to the regulation of credit unions as employers Issues related to liability protections for businesses Issues related to remote notary Issues related to digital identity legislation Issues related Paid Leave Payroll Tax Credits Issues related to Economic Impact Payments Issues related to Fed Accounts Issues related to the Federal Reserve's Main Street Lending Program Issues related to troubled debt restructuring Issues related to Prompt Corective Action requirements Issues related to NCUA subordinated debt rulemaking Issues related to Uniform Residential Loan Application Issues related to digitalization of money Issues related to electronic signatures on wire transfer documents Issues related to cybercriminal activity during COVID-19 Issues related to lender forebearance Issues related to Paycheck Protection Program forgiveness process Issues related to Agriculture Lending Issues related to OCC payment charters Issues related to the Student Empowerment and Financial Literacy Act Issues related to OCC National Bank and Savings Association Digital Activities Issues related to the treatment of certain COVID-19 Loss Mitigation options under RESPA (Reg X) Issues related to premium assessments by the National Credit Union Share Insurance Issues related to the proposed exclusion of PPP Loans from financial institution asset calculations Issues related to Section 4013 of the CARES Act Issues related to Section 4016 of the CARES Act Issues related tot he oversight of prudential regulators Issues related to PAL 1 Program Issues related to credit union asset size thresholds for regulatory compliance Issues related to NCUA MERIT examination system Issues related to NCUA Derivatives rulemaking Issues related to mortgage servicer assistance Issues related to Section 4022 of the CARES Act Issues related to the ability of NCUA to offer forbearance from Prompt Corrective Action Requirements Issues related to Temporarily Excluding Certain Low-Risk Assets from the Credit Union Net Worth Ratio Issues related to London Inter-Bank Offered Rate (LIBOR) Issues related to the regulation of Federal Employment Laws Issues related to the Office of Comptroller Charter Issues related to the Crypto Charter Issues related to the Solar Winds Data Breach Issues related to PPP Loan Necessity Questionnaires Issues related to SBA Economic Injury Disaster Loan Advances Issues related to Seasoned QM Loan Definitions Issues related to FHFA Strategic Plan for 2021-2024 Issues related to GSE Housing Goals Issues related to Member Business Lending Issues related to interest rate caps Issues related to Federal Housing Finance Agency's (FHFA) recapitalization plans Issues related to rental and mortgage payment assistance Issues related to BSA / AML Regulation Issues related to CECL Accounting requirements Issues related to climate control issues and effect on financial institutions Issues related to UDAAP guidance and requirements Issues related to risk-based capital requirements Issues related to NCUA's Communications and Transparency Issues related to Enterprise liquidity framework (FHFA) Issues related to the discussion draft of the Expanding Financial Access for Underserved Communities Act Issues related to the NCUA's Capitalization of Interest in Connection with Loan Workouts and Modifications Rulemaking Issues related to the Federal Reserve's proposed Regulation II Issues related to Capitalizing interest on consumer loans Issues related to Cryptocurrency Issues related to proposed postal banking pilot program Issues related to proposed new tax reporting requirements for financial institutions Issues related to the implementation of consumer financial protection laws Issues related to the safety and soundness regulations of credit unions Issues related to investment authority Issues related to BSA / AML regulation and Cannabis Banking Issues related to rate cap legislation and the Military Lending Act Issues related to credit card interchange fees and routing Issues related to FY22 National Defense Authorization Act Issues related to NCUA Central Liquidity Facility Issues related to Climate and Natural disaster risk management at regulated entities Issues related to PSPA / QM Conflict Issues related to CAMELS proposal Issues related to credit union coverage under GNMA rules Issues related to Cryptocurrency and digital assets Issues related to the re-nomination of Todd Harper to the NCUA Board Issues related to examining frameworks to address future pandemic risk Issues related to the NDAA rate cap proposals Issues related to the collection of checks and other items by Federal Reserve Banks and Funds Transfers through Fedwire Issues related to the potential modifications to the Federal Reserve policy on payment system risk Issues related to Small Business Bankruptcy Issues related to mortgage-backed securities insurance Issues related to the state of the rural economy Issues related to financial barriers to minority and women-owned businesses' involvement in infrastructure projects Issues related to the President's working group on financial market's report on stablecoins Issues related to economic impact of growing burden of medical debt Issues related to the Credit Union Employee and Member Safety Act in the FY2022 Omnibus Appropriations Act Issues related to the Interagency Task Force on Property Appraisal and Valuation Equity (PAVE) appraisals Issues related to the National Defense Authorization Act FY2023 Issues related to the Administration of the CDFI Fund Issues related to Central Bank Digital Currency Issues related to National Flood Insurance Program Reauthorization Issues related to Reg. II, Dodd Frank, Durbin Amendment, Section 107531 Issues related to G20 Rome Leaders Declaration Issues related to the United States Innovation and Competition Act of 2021 Issues related to Prompt Corrective Action: Earnings Retention Waivers and Net Worth Restoration Plans Issues related to Prohibition on Inclusion of Adverse Information in Consumer Reporting in Cases of Human Trafficking Issues related to the Truth in Savings Act (TISA) and Part 707 of the NCUA Rules and Regulations Issues related to 40 Year Term Loan Modifications Issues related to data security and interchange fees Issues related to credit union loan maturity limits Issues related to credit union business lending caps Issues related to the administration of the CDFI Fund Issues related to the National Defense Authorization Act and Interchange fee issues Issues related to CDFI recertification applications Issues related to Protecting military service members and veterans from Financial scams and fraud Issues related to new consumer financial products and the impacts to workers Issues related to making the CFPB Accountable to Small Business Act Issues related to cyber incident notification requirements for Federally insured credit unions Issues related to ensuring responsible development of digital assets Issues related to the CFPB ensuring data aggregation services market is Fair, transparent and competitive H.J. Res 35, providing for Congressional disapproval under Chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders" S.J. Res 15, a joint resolution providing for congressional disapproval under Chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders" H.R. 133, the Consolidated Appropriations Act (2020) H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1395, the Housing Financial Literacy Act of 2021 H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act 0f 2021 H.R. 1996, Secure and Fair Enforcement (SAFE) Banking Act of 2021 H.R. 2040, the Financial Reporting Threshold Modernization Act H.R. 2311, To amend the Federal Credit Union Act to modernize certain processes regarding expulsion of credit union members for cause, and for other purposes H.R. 2471, the Consolidated Appropriations Act of 2022 H.R. 2547, the Comprehensive Debt Collection Improvement Act H.R. 3684, Infrastructure Investment and Jobs Act, Sec. 90005, Extension of enterprise guarantee fees H.R. 3958, Central Liquidity Facility Enhancement Act H.R. 3962, SECURE Notarization Act of 2021 H.R. 4277, Overdraft protection legislation H.R. 4495, the Down payment Toward Equity Act of 2021 H.R. 4773, the Consumer Financial Protection Commission Act H.R. 4905, Promoting New and Diverse Depository Institutions Act H.R. 5189, Member Business Loan Expansion Act H.R. 5206, Tax Gap Reform and IRS Enforcement Act H.R. 5305, Extending Government Funding and Delivering Emergency Assistance Act H.R. 5451, Protecting Financial Privacy Act of 2021 H.R. 5912, the Close the ILC Loophole Act H.R. 6889, Credit Union Board Modernization Act H.R. 7003, Expanding Financial Access to Underserved Communities Act H.R. 7022, the Strengthening Cyber-Security for the Financial Sector Act H.R. 7733, the CDFI Bond Guarantee Program Improvement Act of 2022 H.R. 7900, SAFE Banking, amendment #983 by Representative Beatty (OH), Amendment #543 offered by Representatives Dean (PA), Armstrong (ND), Perlmutter (CO),Reschenthalter (PA) and Escobar (TX) H.R. 8152, American Data Privacy and Protection Act H.R. 8294, the Transportation, Housing and Urban development, Agriculture, Rural development, Energy and Water Development, Financial Services and General Government, Interior, Environment, Military Construction, and Veterans affairs Appropriations Act of Fiscal Year 2023 H.R. 8485, the Expanding Access to Credit through Consumer-Permissioned Data Act S. 254, A bill to establish a Homeowner Assistance Fund at the Department of the Treasury S. 337, Stop Senior Scams Act S. 762, A bill to provide the National Credit Union Administration Board flexibility to increase Federal credit union loan maturities, and for other purposes S. 910, SAFE Banking Act of 2021 S. 1368, American Housing and Economic Mobility Act of 2021 S. 1625, Securing and Enabling Commerce Using Remote and Electronic Notarization Act S. 1767, the Credit Union Employee and Member Safety Act of 2021 S. 2857, Protection Financial Privacy Act of 2021 S. 3715, E-SIGN Modernization Act of 2022 S. 3813, Veterans Member Business Loan Act S. 4325, Credit Union Board Modernization S. 4356, The Responsible Financial Innovation Act S. 4676, Credit Card Competition Act of 2022 S. 4698, Improving Cybersecurity of Credit Unions Act S. 4879, Expanding Financial Access for Underserved Communities Act S. Amendment 6174, National Defense Authorization Act, Report on Credit and Debit Card
Client expense: $979,068 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA), Treasury, Dept of, Veterans Affairs, Dept of (VA)
2022 · fourth_quarter · Banking
Bank On Buy Now, Pay Later Central Bank Digital Currency Cryptocurrency Nominations USPS Pilot Banking Program H.R. 1996, The SAFE Banking Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2561, Promoting Access to Capital in Unbanked Communities Act of 2021 S. 910, SAFE Banking Act S.J.RES.15, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of Currency relating to "National Banks and Federal Savings Associations as Lenders." H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate LIBOR Act H.R. 5189, Member Business Loan Expansion Act S. 2508, Veterans and Consumer Fair Credit Act Perlmutter Amendment (H.Amdt.97) to H.R. 4350, National Defense Authorization Act of 2022 H.R. 2989, Financial Transparency Act H.R. 6145, Community Bank Relief Act of 2021 S. 3409, To amend the Economic Growth, Regulatory Relief, and Consumer Protection Act to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024. Emergency Capital Investment Issues for CDFI and MDI S. 3715, The E-SIGN Modernization Act Coin Circulation S. 3779, Adjustable Interest Rate LIBOR Act H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. H.R. 4277, Overdraft Protection Act of 2021 H.R 4521, America Competes Act of 2022 H.R.7003, Expanding Financial Access for Underserved Communities Act S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on Banking. H.R. 2543, Federal Reserve Racial and Economic Equity Act UDAAP Supervisory Policies and Adjudication Procedures Issues impacting the modernization of the Community Reinvestment Act Deposit Insurance Assessment Rates S.4674, Credit Card Competition Act H.R. 8874, Credit Card Competition Act H.R. 8485, Expanding Access to Credit through Consumer-Permissioned Data Act S.4760, Digital Commodities Consumer Protection Act of 2022 Merchant Category Codes
Client expense: $2,840,000 · Firm income: Not reported
Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2022 · fourth_quarter · Financial Institutions/Investments/Securities
H.R. 1996 - SAFE Banking Act, S.J.Res15/H.J.Res35
Client expense: Not reported · Firm income: $45,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2022 · fourth_quarter · Financial Institutions/Investments/Securities
1. Basel Capital and Liquidity Treatment for asset-backed securities - General issues concerning the appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules (includes the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book, efforts to create "Simple, Transparent and Comparable" (STC) securitizations, STC treatment for short-term securitizations, and capital treatment of consolidated SPEs when risk transfer occurs). 2. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II for all ABS asset classes, specifically auto, credit card, equipment lease and student loans. 3. General Dodd-Frank Implementation and Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention, the Liquidity Coverage Ratio (LCR), and uncleared swap margin rules; issues related to risk retention provisions, the Volcker Rule (discussed SFA's recommended changes with staff at SEC, Federal Reserve Board, FDIC and OCC), arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; the implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018, specifically provisions potentially related to securitization. 4. SFA is a member of the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York working to determine best path for transition away from LIBOR (in 2021, the U.K.s Financial Conduct Authority will stop compelling banks to report LIBOR). SFA co-chairs the ARRCs Securitization Working Group which meets regularly with the goal of producing concrete recommendations on how best to effect the transition. 5. Advocacy related to industry concerns regarding the Bureaus proposed consent judgment in the case of Consumer Financial Protection Bureau v. National Collegiate Master Student Loan Trusts. This case has broad implications for the securitization market as the consent order could alter the parties settled contractual rights and obligations in these transactions. 6. Employee Retirement Income Security Act of 1974 (ERISA) - Issues relating to the interpretation and implementation of amendments and exemptions to ERISA as they relate to structured finance; issues related to ERISA disclosures provided in securitization offering documents. 7. Trust Indenture Act of 1939 (TIA) - Issues relating to a potential conflict with a provision of the Trust Indenture Act - allowing for a clarification to be limited to the LIBOR transition event and eliminating the potential of setting an unintended precedent. 8. True Lender - Issues relating to the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J. Res. 15. 9. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 10. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021, and its inclusion in the Consolidated Appropriations Act, 2022. 11. SEC Rule 15c2-11 - Advocacy related to concerns regarding the rule's public disclosure requirements, and a push for delayed implementation or complete rule reversal.
Client expense: $271,430 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2022 · fourth_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP) conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J. Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022.
Client expense: $271,430 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2022 · fourth_quarter · Banking
Cryptocurrency, mobile payments, fraud, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy, the Federal Reserve and big data, CFPB prepaid products rule (Prepaid Accounts Under Direct Electronic Transfer Act {Regulation E} and the Truth in Lending Act), Federal Reserve Secure Payments Task Force, Marketplace lending, H.R. 10- Financial Choice Act of 2017, H.J. Res. 62/72-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 prepaid accounts under the Electronic Fund Transfer Act and the Truth in Lending Act, S.J.Res.19 - A joint resolution 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 prepaid accounts under the Electronic Fund Transfer Act and the Truth in Lending Act, H. R. 1801-To delay the effective date of the final rule of the Bureau of Consumer Financial Protection titled Prepaid Accounts under the Electronic Fund Transfer Act (Regulation E) and the Truth In Lending Act (Regulation Z)", S. 387-Consumer Financial Protection Bureau Accountability Act of 2017, S. 626-CFPB-IG Act of 2017. CFPB Governance Structure. H.J.Res. 111, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements." S.J.Res. 47, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements". H.R. 4439, Modernizing Credit Opportunities Act of 2017. H.R. 3299, Protecting Consumers' Access to Credit Act of 2017. S. 1642, Protecting Consumers' Access to Credit Act of 2017. H.R. 3354, Make America Secure & Prosperous Appropriations Act. H.R. 6743, Consumer Information Notification Requirement Act. H.R. 6850, Financial Reporting Threshold Modernization Act. "Potential Federal Reserve Actions To Support Interbank Settlement of Faster Payments, Request for Comments" (Docket # OP-1625). OCC ANPR "Reforming the Community Reinvestment Act Regulatory Framework" (Docket # OCC-2018- 0008). H.R. 1595, "SAFE Banking Act of 2019". FDIC Request for Information on Small-Dollar Lending (Docket No. RIN 3064-ZA04). S. 1200, Secure And Fair Enforcement Banking Act of 2019. H.R. 4813, Keep Big Tech Out of Finance Act. S. 2839, Eliminating Corporate Shadow Banking Act of 2019. S. 1951, Designing Accounting Safeguards To Help Broaden Oversight and Regulations on Data. H.R. 5574, "Preserving Small Business Lending Act of 2020." H.R. 6116, "Consumer Financial Protection Commission Act." S. 3548, "CARES Act." H.R. 6379, "Take Responsibility for Workers and Families Act." H.R. 748, "CARES Act." S. 3990, "Financial Product Safety Commission Act of 2020." H.R. 6886, "Paycheck Protection Program Flexibility Act of 2020." H.R. 710, "Paycheck Protection Program Flexibility Act of 2020." S.4116, "Bill to extend Paycheck Protection Program..." H.R. 8087, "Bill to extend Paycheck Protection Program..." H.R. 7777, "Paycheck Protection Small Business Forgiveness Act." H.R. 8265, "To amend the Small Business Act and the CARES Act to establish a program for second draw loans and make other modifications to the paycheck protection program and for other purposes..." S. 4614, "Postal Banking Act." H.R. 8406, "HEROS Act." H.R. 7889, "Small Business Lending Disclosure and Broker Regulation Act of 2020." OCC "True Lender." OCC "National Bank and Federal Savings Association Digital Activities." H.R. 8215, "Improving Digital Identity Act of 2020." U.S. House Committee on Financial Services' Task Force on Financial Technology and Task Force on Artificial Intelligence. S. 4999, "Emergency Direct Payments for Families and Workers Act of 2020." H.R. 8893, "Coronavirus Assistance for Americans Families Act." S. 4927, EIDL Forgiveness Act." H.R. 8827, "Stablecoin Classification and Regulation Act of 2020." S. 4800, "The Heroes Act." H.R. 8721, "Public Banking Act of 2020." S.J. Res 15, "True Lender." H.J. Res 35, "True Lender." H.R. 296, "Financial Technology Protection Act." H.R. 1602, "Eliminate Barriers to Innovation Act of 2021." H.R. 1996, "SAFE Banking Act of 2021." H.R. 2561, "Promoting Access to Capital in Underbanked Communities Act of 2021." H.R. 5045, "Blockchain Certainty Act." H.R. 4741, "Digital Asset Market Structure and Investor Protection Act," S. 3906, "Small Business Broadband and Emerging Information Technology Enhancement Act of 2022," S. 3970, "Stablecoin Transparency Act," H.R. 7231, "ECASH Act," H.R. 5912, "Close the ILC Loophole Act," S. 4356, "Responsible Financial Innovation Act," H.R. 7614, "Digital Commodity Exchange Act of 2022," S. 3970, "Stablecoin Transparency Act, "H.R. 3425, "Saving Gig Economy Taxpayers Act." S. 4946, "Payments Modernization Act of 2022." S. 4760, "Digital Commodities Consumer Protection Act of 2022." H.R. 8874, "Credit Card Competition Act of 2022." S. 4674, "Credit Card Competition Act of 2022." S. 4831, "No CBDC Act."
Client expense: $410,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Council of Economic Advisers (CEA), Federal Communications Commission (FCC), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Economic Council (NEC), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of, U.S. Trade Representative (USTR)
2022 · third_quarter · Financial Institutions/Investments/Securities
H.R. 1996 - SAFE Banking Act, S.J.Res15/H.J.Res35
Client expense: Not reported · Firm income: $45,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2022 · third_quarter · Banking
1) Maintain Stop Biased Banking website. No specific legislation. 2) Repeal Foreign Account Tax Compliance Act. No specific legislation. 3) Oppose Federal Reserve establishing a real-time payment system - 83 FR 57351 4) Oppose expansion of Dodd-Franks Durbin Amendment to credit cards. No specific legislation. 5) Oppose overturning the True Lender rule - S.J. Res. 15. 6) Oppose SEC proposal interfering in private partnership agreements between investors and private fund advisers. [Release Nos. IA-5955; File No. S7-03-22]
Client expense: Not reported · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of
2022 · second_quarter · Banking
1) Maintain Stop Biased Banking website. No specific legislation. 2) Repeal Foreign Account Tax Compliance Act. No specific legislation. 3) Oppose Federal Reserve establishing a real-time payment system - 83 FR 57351 4) Oppose expansion of Dodd-Franks Durbin Amendment to credit cards. No specific legislation. 5) Oppose overturning the True Lender rule - S.J. Res. 15. 6) Oppose SEC proposal interfering in private partnership agreements between investors and private fund advisers. [Release Nos. IA-5955; File No. S7-03-22]
Client expense: Not reported · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of
2022 · first_quarter · Banking
1) Maintain Stop Biased Banking website. No specific legislation. 2) Repeal Foreign Account Tax Compliance Act. No specific legislation. 3) Oppose Federal Reserve establishing a real-time payment system - 83 FR 57351 4) Oppose expansion of Dodd-Franks Durbin Amendment to credit cards. No specific legislation. 5) Oppose overturning the True Lender rule - S.J. Res. 15.
Client expense: Not reported · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2022 · third_quarter · Banking
Bank On Buy Now, Pay Later Central Bank Digital Currency Cryptocurrency Nominations USPS Pilot Banking Program H.R. 1996, The SAFE Banking Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2561, Promoting Access to Capital in Unbanked Communities Act of 2021 S. 910, SAFE Banking Act S.J.RES.15, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of Currency relating to "National Banks and Federal Savings Associations as Lenders." H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate LIBOR Act H.R. 5189, Member Business Loan Expansion Act S. 2508, Veterans and Consumer Fair Credit Act Perlmutter Amendment (H.Amdt.97) to H.R. 4350, National Defense Authorization Act of 2022 H.R. 2989, Financial Transparency Act H.R. 6145, Community Bank Relief Act of 2021 S. 3409, To amend the Economic Growth, Regulatory Relief, and Consumer Protection Act to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024. Emergency Capital Investment Issues for CDFI and MDI S. 3715, The E-SIGN Modernization Act Coin Circulation S. 3779, Adjustable Interest Rate LIBOR Act H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. H.R. 4277, Overdraft Protection Act of 2021 H.R 4521, America Competes Act of 2022 H.R.7003, Expanding Financial Access for Underserved Communities Act S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on Banking. H.R. 2543, Federal Reserve Racial and Economic Equity Act UDAAP Supervisory Policies and Adjudication Procedures Issues impacting the modernization of the Community Reinvestment Act Deposit Insurance Assessment Rates S.4674, Credit Card Competition Act H.R. 8874, Credit Card Competition Act H.R. 8485, Expanding Access to Credit through Consumer-Permissioned Data Act S.4760, Digital Commodities Consumer Protection Act of 2022 Merchant Category Codes
Client expense: $2,870,000 · Firm income: Not reported
Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2022 · third_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP) conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J. Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022.
Client expense: $258,964 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2022 · third_quarter · Financial Institutions/Investments/Securities
1. Basel Capital and Liquidity Treatment for asset-backed securities - General issues concerning the appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules (includes the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book, efforts to create "Simple, Transparent and Comparable" (STC) securitizations, STC treatment for short-term securitizations, and capital treatment of consolidated SPEs when risk transfer occurs). 2. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II for all ABS asset classes, specifically auto, credit card, equipment lease and student loans. 3. General Dodd-Frank Implementation and Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention, the Liquidity Coverage Ratio (LCR), and uncleared swap margin rules; issues related to risk retention provisions, the Volcker Rule (discussed SFA's recommended changes with staff at SEC, Federal Reserve Board, FDIC and OCC), arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; the implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018, specifically provisions potentially related to securitization. 4. SFA is a member of the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York working to determine best path for transition away from LIBOR (in 2021, the U.K.s Financial Conduct Authority will stop compelling banks to report LIBOR). SFA co-chairs the ARRCs Securitization Working Group which meets regularly with the goal of producing concrete recommendations on how best to effect the transition. 5. Advocacy related to industry concerns regarding the Bureaus proposed consent judgment in the case of Consumer Financial Protection Bureau v. National Collegiate Master Student Loan Trusts. This case has broad implications for the securitization market as the consent order could alter the parties settled contractual rights and obligations in these transactions. 6. Employee Retirement Income Security Act of 1974 (ERISA) - Issues relating to the interpretation and implementation of amendments and exemptions to ERISA as they relate to structured finance; issues related to ERISA disclosures provided in securitization offering documents. 7. Trust Indenture Act of 1939 (TIA) - Issues relating to a potential conflict with a provision of the Trust Indenture Act - allowing for a clarification to be limited to the LIBOR transition event and eliminating the potential of setting an unintended precedent. 8. True Lender - Issues relating to the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J. Res. 15. 9. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 10. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021, and its inclusion in the Consolidated Appropriations Act, 2022.
Client expense: $258,964 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2022 · third_quarter · Banking
Issues related to Federal Credit Union Charter Modernization Issues related to credit union operations Issues related to credit union field of membership Issues related to credit union service organization Issues related to NCUA's low income designation regulation Issues related to NCUA examination procedures Issues related to NCUA's regulation regarding liquidity Issues related to NCUA's rulemaking process Issues related to NCUA's regulatory review process Issues related to Federal Credit Union Bylaws Issues related to credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union By-Laws Issues related to credit unions' incidental powers Issues related to credit union service to marijuana businesses Issues related to material loss reports of the NCUA Office of Inspector General Issues related to the regulation of corporate credit unions Issues related to fixed assets Issues related to credit union conversions Issues related to credit union call report modernization Issues related to NCUA's Corporate Credit Union Stabilization Plan Issues related to NCUA's budget and the overhead transfer rate Issues related to Credit Union Service Organizations (CUSO) Issues related to the authority of the CFPB to exempt credit unions from its rulemaking Issues related to the CFPB rule to remittances and international wire transfers Issues related to CFPB's Leadership structure and Installing a Board rather than a Director Issues related to codifying the CFPB's Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to overdraft protection and check ordering practices Issues related to mortgage servicing Issues related to mortgage loan originator compensation and qualifications Issues related to the CFPB's rule regarding qualified mortgage / ability to repay Issues related to the CFPB's regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the CFPB's regulation on Truth-In-Lending Act / Real Estate Settlement Procedures Act Integrated Disclosures Issues related to the payday, vehicle title, and similar lending Issues related to short term lending products and advance deposit products Issues related to the CFPB's consumer complaint database Issues related to the CFPB's consumer complaint database Issues related to the Department of Justice's investigation entitled, "Operation Choke Point" Issues related to indirect auto lending Issues related to credit union service to unbanked and underbanked consumers Issues related to the Financial Accounting Standards Board (FASB) Issues related to data and cyber security Issues related to mobile banking and mobile payments Issues related to identity theft and fraud reduction Issues related to secure payments Issues related to merchant data breaches Issues related to the payments system and innovation Issues related to the Fed's implementation of same-day ACH Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements Issues related to the oversight of the Federal Housing Administration Issues related to the USDA Rural Development Loan Program Issues related to the Federal Home Loan Bank System Issues related to membership eligibility in the Federal Home Loan Bank System Issues related to financial literacy Issues related to Housing Finance Reform Issues related to student lending Issues related to the Economic Growth and Regulatory Paperwork Reduction Act Process Issues related to retirement security Issues related to flood insurance Issues related to consumer's access to records Issues related to Interchange Fees Issues related to the Equal Credit Opportunity Act Issues related to the Fair Housing Act Issues related to the merger of credit unions Issues related to the Real Estate Settlement Procedures Act Issues related to Community Reinvestment Act Issues related to Regulation Z Issues related to Military Lending Act Issues related to Financial Technology Issues related to Small Business Lending Data Collection requirements Issues related to Involuntary liquidation of Federal Credit Unions and Claims Procedures Issues related to Web-Bases Quantitative Testing of Point of Sale / ATM Overdraft Disclosure Forms Issues related to residential appraisals Issues related to FHA appraisal certification Issues related to FHA and USDA Loan Modifications Issues related to Faster Payments Issues related to the Fair Credit Reporting Act Issues related to cooperative funding sources in federal appropriations legislation Issues related to regulation of debt collection activity Issues related to capital reform for credit unions Issues related to diversity and inclusion in Financial Services Issues related to Section 124 of the Federal Credit Union Act Issues related to the Consumer Financial Protection Bureau's No-Action Letters and the BCFP Product Sandbox Issues related to enterprise validation and approval of credit score models Issues related to the availability of Funds and Collection of Checks (Regulation CC) Issues related to arbitration clauses Issues related to SBA 7(a) loan program Issues related to financial institutions operating on military installations Issues related to postal banking Issues related to Telephone Consumer Protection Act Issues related to financial technology (FINTECH) Issues related to robocalls and the draft Declatory Ruling (the ruling) and Third Further Notice of Proposted Rulemaking (FNPRM) CG Docket No 17-59, WC Docket No. 17 - 97 Issues related to payday and small dollar lending Issues related to leases of non-excess property on military bases Issues related to Opportunity Zones Issues related to minority homeownership Issues related to the ability of Federal Credit unions to establish their own fiscal year Issues related to a requirement that Federal credit unions file certain information regarding loan officers Issues related to enhancing flexibility of Federal Credit Unions to schedule board meetings Issues related to removing certain outdated responsibilites of Federal credit union board of directors Issues related to permitting Federal credit unions to expel disruptive members for just cause without a vote Issues related to permitting balloting for conversions from state to federal charter and from federal to state charter to be conducted electronically Issues related to PACE Loans Issues related to minority depository insitutions Issues related to AI and cloud computing Issues related to the Consumer Online Privacy Rights Act Issues related to COVID-19 crisis response legislation Issues related to the Paycheck Protection Program Issues related to Taxi Medallion loans Issues related to QRM Risk Retection Review Issues related to NCUA's proposed rule on combination transactions Issues related to the regulation of credit unions as employers Issues related to liability protections for businesses Issues related to remote notary Issues related to digital identity legislation Issues related Paid Leave Payroll Tax Credits Issues related to Economic Impact Payments Issues related to Fed Accounts Issues related to the Federal Reserve's Main Street Lending Program Issues related to troubled debt restructuring Issues related to Prompt Corective Action requirements Issues related to NCUA subordinated debt rulemaking Issues related to Uniform Residential Loan Application Issues related to digitalization of money Issues related to electronic signatures on wire transfer documents Issues related to cybercriminal activity during COVID-19 Issues related to lender forebearance Issues related to Paycheck Protection Program forgiveness process Issues related to Agriculture Lending Issues related to OCC payment charters Issues related to the Student Empowerment and Financial Literacy Act Issues related to OCC National Bank and Savings Association Digital Activities Issues related to the treatment of certain COVID-19 Loss Mitigation options under RESPA (Reg X) Issues related to premium assessments by the National Credit Union Share Insurance Issues related to the proposed exclusion of PPP Loans from financial institution asset calculations Issues related to Section 4013 of the CARES Act Issues related to Section 4016 of the CARES Act Issues related tot he oversight of prudential regulators Issues related to PAL 1 Program Issues related to credit union asset size thresholds for regulatory compliance Issues related to NCUA MERIT examination system Issues related to NCUA Derivatives rulemaking Issues related to mortgage servicer assistance Issues related to Section 4022 of the CARES Act Issues related to the ability of NCUA to offer forbearance from Prompt Corrective Action Requirements Issues related to Temporarily Excluding Certain Low-Risk Assets from the Credit Union Net Worth Ratio Issues related to London Inter-Bank Offered Rate (LIBOR) Issues related to the regulation of Federal Employment Laws Issues related to the Office of Comptroller Charter Issues related to the Crypto Charter Issues related to the Solar Winds Data Breach Issues related to PPP Loan Necessity Questionnaires Issues related to SBA Economic Injury Disaster Loan Advances Issues related to Seasoned QM Loan Definitions Issues related to FHFA Strategic Plan for 2021-2024 Issues related to GSE Housing Goals Issues related to Member Business Lending Issues related to interest rate caps Issues related to Federal Housing Finance Agency's (FHFA) recapitalization plans Issues related to rental and mortgage payment assistance Issues related to BSA / AML Regulation Issues related to CECL Accounting requirements Issues related to climate control issues and effect on financial institutions Issues related to UDAAP guidance and requirements Issues related to risk-based capital requirements Issues related to NCUA's Communications and Transparency Issues related to Enterprise liquidity framework (FHFA) Issues related to the discussion draft of the Expanding Financial Access for Underserved Communities Act Issues related to the NCUA's Capitalization of Interest in Connection with Loan Workouts and Modifications Rulemaking Issues related to the Federal Reserve's proposed Regulation II Issues related to Capitalizing interest on consumer loans Issues related to Cryptocurrency Issues related to proposed postal banking pilot program Issues related to proposed new tax reporting requirements for financial institutions Issues related to the implementation of consumer financial protection laws Issues related to the safety and soundness regulations of credit unions Issues related to investment authority Issues related to BSA / AML regulation and Cannabis Banking Issues related to rate cap legislation and the Military Lending Act Issues related to credit card interchange fees and routing Issues related to FY22 National Defense Authorization Act Issues related to NCUA Central Liquidity Facility Issues related to Climate and Natural disaster risk management at regulated entities Issues related to PSPA / QM Conflict Issues related to CAMELS proposal Issues related to credit union coverage under GNMA rules Issues related to Cryptocurrency and digital assets Issues related to the re-nomination of Todd Harper to the NCUA Board Issues related to examining frameworks to address future pandemic risk Issues related to the NDAA rate cap proposals Issues related to the collection of checks and other items by Federal Reserve Banks and Funds Transfers through Fedwire Issues related to the potential modifications to the Federal Reserve policy on payment system risk Issues related to Small Business Bankruptcy Issues related to mortgage-backed securities insurance Issues related to the state of the rural economy Issues related to financial barriers to minority and women-owned businesses' involvement in infrastructure projects Issues related to the President's working group on financial market's report on stablecoins Issues related to economic impact of growing burden of medical debt Issues related to the Credit Union Employee and Member Safety Act in the FY2022 Omnibus Appropriations Act Issues related to the Interagency Task Force on Property Appraisal and Valuation Equity (PAVE) appraisals Issues related to the National Defense Authorization Act FY2023 Issues related to the Administration of the CDFI Fund Issues related to Central Bank Digital Currency Issues related to National Flood Insurance Program Reauthorization Issues related to Reg. II, Dodd Frank, Durbin Amendment, Section 107531 Issues related to G20 Rome Leaders Declaration Issues related to the United States Innovation and Competition Act of 2021 Issues related to Prompt Corrective Action: Earnings Retention Waivers and Net Worth Restoration Plans Issues related to Prohibition on Inclusion of Adverse Information in Consumer Reporting in Cases of Human Trafficking Issues related to the Truth in Savings Act (TISA) and Part 707 of the NCUA Rules and Regulations Issues related to 40 Year Term Loan Modifications Issues related to data security and interchange fees Issues related to credit union loan maturity limits Issues related to credit union business lending caps Issues related to the administration of the CDFI Fund Issues related to the National Defense Authorization Act and Interchange fee issues Issues related to CDFI recertification applications Issues related to Protecting military service members and veterans from Financial scams and fraud Issues related to new consumer financial products and the impacts to workers Issues related to making the CFPB Accountable to Small Business Act Issues related to cyber incident notification requirements for Federally insured credit unions Issues related to ensuring responsible development of digital assets Issues related to the CFPB ensuring data aggregation services market is Fair, transparent and competitive H.J. Res 35, providing for Congressional disapproval under Chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders" S.J. Res 15, a joint resolution providing for congressional disapproval under Chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders" H.R. 133, the Consolidated Appropriations Act (2020) H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1395, the Housing Financial Literacy Act of 2021 H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act 0f 2021 H.R. 1996, Secure and Fair Enforcement (SAFE) Banking Act of 2021 H.R. 2040, the Financial Reporting Threshold Modernization Act H.R. 2311, To amend the Federal Credit Union Act to modernize certain processes regarding expulsion of credit union members for cause, and for other purposes H.R. 2471, the Consolidated Appropriations Act of 2022 H.R. 2547, the Comprehensive Debt Collection Improvement Act H.R. 3684, Infrastructure Investment and Jobs Act, Sec. 90005, Extension of enterprise guarantee fees H.R. 3958, Central Liquidity Facility Enhancement Act H.R. 3962, SECURE Notarization Act of 2021 H.R. 4277, Overdraft protection legislation H.R. 4495, the Down payment Toward Equity Act of 2021 H.R. 4773, the Consumer Financial Protection Commission Act H.R. 4905, Promoting New and Diverse Depository Institutions Act H.R. 5189, Member Business Loan Expansion Act H.R. 5206, Tax Gap Reform and IRS Enforcement Act H.R. 5305, Extending Government Funding and Delivering Emergency Assistance Act H.R. 5451, Protecting Financial Privacy Act of 2021 H.R. 5912, the Close the ILC Loophole Act H.R. 6889, Credit Union Board Modernization Act H.R. 7003, Expanding Financial Access to Underserved Communities Act H.R. 7022, the Strengthening Cyber-Security for the Financial Sector Act H.R. 7733, the CDFI Bond Guarantee Program Improvement Act of 2022 H.R. 7900, SAFE Banking, amendment #983 by Representative Beatty (OH), Amendment #543 offered by Representatives Dean (PA), Armstrong (ND), Perlmutter (CO),Reschenthalter (PA) and Escobar (TX) H.R. 8152, American Data Privacy and Protection Act H.R. 8294, the Transportation, Housing and Urban development, Agriculture, Rural development, Energy and Water Development, Financial Services and General Government, Interior, Environment, Military Construction, and Veterans affairs Appropriations Act of Fiscal Year 2023 H.R. 8485, the Expanding Access to Credit through Consumer-Permissioned Data Act S. 254, A bill to establish a Homeowner Assistance Fund at the Department of the Treasury S. 337, Stop Senior Scams Act S. 762, A bill to provide the National Credit Union Administration Board flexibility to increase Federal credit union loan maturities, and for other purposes S. 910, SAFE Banking Act of 2021 S. 1368, American Housing and Economic Mobility Act of 2021 S. 1625, Securing and Enabling Commerce Using Remote and Electronic Notarization Act S. 1767, the Credit Union Employee and Member Safety Act of 2021 S. 2857, Protection Financial Privacy Act of 2021 S. 3715, E-SIGN Modernization Act of 2022 S. 3813, Veterans Member Business Loan Act S. 4325, Credit Union Board Modernization S. 4356, The Responsible Financial Innovation Act S. 4676, Credit Card Competition Act of 2022 S. 4698, Improving Cybersecurity of Credit Unions Act S. 4879, Expanding Financial Access for Underserved Communities Act S. Amendment 6174, National Defense Authorization Act, Report on Credit and Debit Card
Client expense: $1,070,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA), Treasury, Dept of, Veterans Affairs, Dept of (VA)
2022 · third_quarter · Financial Institutions/Investments/Securities
Federal policy relating to anticipated Consumer Financial Protection Bureau regulation of consumer financial services including payday lending, auto title lending, and regulatory process. Potential legislation to regulate interest rates on financial products. S.J. Res. 15 - A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders." Implementation of the CARES Act (PL 116-136), provisions relating to the payroll protection program. Implementation of the American Rescue Plan Act of 2021 (PL-117-2), provisions relating to the payroll protection program. Legislative proposals relating to prohibiting retail businesses from refusing cash payments. H.R. 2040, The Financial Reporting Threshold Modernization Act, provisions relating to updating thresholds for certain currency transaction reports and suspicious activity reports. H.R. 1996, The SAFE Banking Act of 2021, provisions relating to the provision of financial services to cannabis-related businesses and service providers S. 563, The Fair Access to Banking Act, provisions relating to fair access to financial services and discount window lending programs. Veterans and Consumers Fair Credit Act (H.R. 5974/S. 2508), provisions relating to regulation of interest rates on financial products.
Client expense: Not reported · Firm income: $50,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2022 · third_quarter · Banking
Cryptocurrency, mobile payments, fraud, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy, the Federal Reserve and big data, CFPB prepaid products rule (Prepaid Accounts Under Direct Electronic Transfer Act {Regulation E} and the Truth in Lending Act), Federal Reserve Secure Payments Task Force, Marketplace lending, H.R. 10- Financial Choice Act of 2017, H.J. Res. 62/72-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 prepaid accounts under the Electronic Fund Transfer Act and the Truth in Lending Act, S.J.Res.19 - A joint resolution 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 prepaid accounts under the Electronic Fund Transfer Act and the Truth in Lending Act, H. R. 1801-To delay the effective date of the final rule of the Bureau of Consumer Financial Protection titled Prepaid Accounts under the Electronic Fund Transfer Act (Regulation E) and the Truth In Lending Act (Regulation Z)", S. 387-Consumer Financial Protection Bureau Accountability Act of 2017, S. 626-CFPB-IG Act of 2017. CFPB Governance Structure. H.J.Res. 111, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements." S.J.Res. 47, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements". H.R. 4439, Modernizing Credit Opportunities Act of 2017. H.R. 3299, Protecting Consumers' Access to Credit Act of 2017. S. 1642, Protecting Consumers' Access to Credit Act of 2017. H.R. 3354, Make America Secure & Prosperous Appropriations Act. H.R. 6743, Consumer Information Notification Requirement Act. H.R. 6850, Financial Reporting Threshold Modernization Act. "Potential Federal Reserve Actions To Support Interbank Settlement of Faster Payments, Request for Comments" (Docket # OP-1625). OCC ANPR "Reforming the Community Reinvestment Act Regulatory Framework" (Docket # OCC-2018- 0008). H.R. 1595, "SAFE Banking Act of 2019". FDIC Request for Information on Small-Dollar Lending (Docket No. RIN 3064-ZA04). S. 1200, Secure And Fair Enforcement Banking Act of 2019. H.R. 4813, Keep Big Tech Out of Finance Act. S. 2839, Eliminating Corporate Shadow Banking Act of 2019. S. 1951, Designing Accounting Safeguards To Help Broaden Oversight and Regulations on Data. H.R. 5574, "Preserving Small Business Lending Act of 2020." H.R. 6116, "Consumer Financial Protection Commission Act." S. 3548, "CARES Act." H.R. 6379, "Take Responsibility for Workers and Families Act." H.R. 748, "CARES Act." S. 3990, "Financial Product Safety Commission Act of 2020." H.R. 6886, "Paycheck Protection Program Flexibility Act of 2020." H.R. 710, "Paycheck Protection Program Flexibility Act of 2020." S.4116, "Bill to extend Paycheck Protection Program..." H.R. 8087, "Bill to extend Paycheck Protection Program..." H.R. 7777, "Paycheck Protection Small Business Forgiveness Act." H.R. 8265, "To amend the Small Business Act and the CARES Act to establish a program for second draw loans and make other modifications to the paycheck protection program and for other purposes..." S. 4614, "Postal Banking Act." H.R. 8406, "HEROS Act." H.R. 7889, "Small Business Lending Disclosure and Broker Regulation Act of 2020." OCC "True Lender." OCC "National Bank and Federal Savings Association Digital Activities." H.R. 8215, "Improving Digital Identity Act of 2020." U.S. House Committee on Financial Services' Task Force on Financial Technology and Task Force on Artificial Intelligence. S. 4999, "Emergency Direct Payments for Families and Workers Act of 2020." H.R. 8893, "Coronavirus Assistance for Americans Families Act." S. 4927, EIDL Forgiveness Act." H.R. 8827, "Stablecoin Classification and Regulation Act of 2020." S. 4800, "The Heroes Act." H.R. 8721, "Public Banking Act of 2020." S.J. Res 15, "True Lender." H.J. Res 35, "True Lender." H.R. 296, "Financial Technology Protection Act." H.R. 1602, "Eliminate Barriers to Innovation Act of 2021." H.R. 1996, "SAFE Banking Act of 2021." H.R. 2561, "Promoting Access to Capital in Underbanked Communities Act of 2021." H.R. 5045, "Blockchain Certainty Act." H.R. 4741, "Digital Asset Market Structure and Investor Protection Act," S. 3906, "Small Business Broadband and Emerging Information Technology Enhancement Act of 2022," S. 3970, "Stablecoin Transparency Act," H.R. 7231, "ECASH Act," H.R. 5912, "Close the ILC Loophole Act," S. 4356, "Responsible Financial Innovation Act," H.R. 7614, "Digital Commodity Exchange Act of 2022," S. 3970, "Stablecoin Transparency Act, "H.R. 3425, "Saving Gig Economy Taxpayers Act." S. 4946, "Payments Modernization Act of 2022." S. 4760, "Digital Commodities Consumer Protection Act of 2022." H.R. 8874, "Credit Card Competition Act of 2022." S. 4674, "Credit Card Competition Act of 2022." S. 4831, "No CBDC Act."
Client expense: $410,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Council of Economic Advisers (CEA), Federal Communications Commission (FCC), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Economic Council (NEC), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of, U.S. Trade Representative (USTR)
2022 · second_quarter · Banking
Bank On Buy Now, Pay Later Central Bank Digital Currency Cryptocurrency Durbin Interchange Nominations USPS Pilot Banking Program H.R. 1996, The SAFE Banking Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2561, Promoting Access to Capital in Unbanked Communities Act of 2021 S. 910, SAFE Banking Act S.J.RES.15, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of Currency relating to "National Banks and Federal Savings Associations as Lenders." H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate LIBOR Act H.R. 5189, Member Business Loan Expansion Act S. 2508, Veterans and Consumer Fair Credit Act Perlmutter Amendment (H.Amdt.97) to H.R. 4350, National Defense Authorization Act of 2022 H.R. 2989, Financial Transparency Act H.R. 6145, Community Bank Relief Act of 2021 S. 3409, To amend the Economic Growth, Regulatory Relief, and Consumer Protection Act to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024. Emergency Capital Investment Issues for CDFI and MDI S. 3715, The E-SIGN Modernization Act Coin Circulation S. 3779, Adjustable Interest Rate LIBOR Act H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. H.R. 4277, Overdraft Protection Act of 2021 H.R 4521, America Competes Act of 2022 H.R.7003, Expanding Financial Access for Underserved Communities Act S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on Banking. H.R. 2543, Federal Reserve Racial and Economic Equity Act UDAAP Supervisory Policies and Adjudication Procedures Bank On Buy Now, Pay Later Central Bank Digital Currency Cryptocurrency Durbin Interchange Nominations USPS Pilot Banking Program H.R. 1996, The SAFE Banking Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2561, Promoting Access to Capital in Unbanked Communities Act of 2021 S. 910, SAFE Banking Act S.J.RES.15, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of Currency relating to "National Banks and Federal Savings Associations as Lenders." H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate LIBOR Act H.R. 5189, Member Business Loan Expansion Act S. 2508, Veterans and Consumer Fair Credit Act Perlmutter Amendment (H.Amdt.97) to H.R. 4350, National Defense Authorization Act of 2022 H.R. 2989, Financial Transparency Act H.R. 6145, Community Bank Relief Act of 2021 S. 3409, To amend the Economic Growth, Regulatory Relief, and Consumer Protection Act to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024. Emergency Capital Investment Issues for CDFI and MDI S. 3715, The E-SIGN Modernization Act Coin Circulation S. 3779, Adjustable Interest Rate LIBOR Act H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. H.R. 4277, Overdraft Protection Act of 2021 H.R 4521, America Competes Act of 2022 H.R.7003, Expanding Financial Access for Underserved Communities Act S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on Banking. H.R. 2543, Federal Reserve Racial and Economic Equity Act UDAAP Supervisory Policies and Adjudication Procedures
Client expense: $1,740,000 · Firm income: Not reported
Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2022 · first_quarter · Banking
Bank On Buy Now, Pay Later Central Bank Digital Currency Cryptocurrency Durbin Interchange Nominations USPS Pilot Banking Program H.R. 1996, The SAFE Banking Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2561, Promoting Access to Capital in Unbanked Communities Act of 2021 S. 910, SAFE Banking Act S.J.RES.15, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of Currency relating to "National Banks and Federal Savings Associations as Lenders." H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate LIBOR Act H.R. 5189, Member Business Loan Expansion Act S. 2508, Veterans and Consumer Fair Credit Act Perlmutter Amendment (H.Amdt.97) to H.R. 4350, National Defense Authorization Act of 2022 H.R. 2989, Financial Transparency Act H.R. 6145, Community Bank Relief Act of 2021 S. 3409, To amend the Economic Growth, Regulatory Relief, and Consumer Protection Act to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024. Emergency Capital Investment Issues for CDFI and MDI S. 3715, The E-SIGN Modernization Act Coin Circulation S. 3779, Adjustable Interest Rate LIBOR Act H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. H.R. 4277, Overdraft Protection Act of 2021 H.R 4521, America Competes Act of 2022 H.R.7003, Expanding Financial Access for Underserved Communities Act
Client expense: $1,666,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2022 · second_quarter · Banking
Issues related to Federal Credit Union Charter Modernization Issues related to credit union operations Issues related to credit union field of membership Issues related to credit union service organization Issues related to NCUA's low income designation regulation Issues related to NCUA examination procedures Issues related to NCUA's regulation regarding liquidity Issues related to NCUA's rulemaking process Issues related to NCUA's regulatory review process Issues related to Federal Credit Union Bylaws Issues related to credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union By-Laws Issues related to credit unions' incidental powers Issues related to credit union service to marijuana businesses Issues related to material loss reports of the NCUA Office of Inspector General Issues related to the regulation of corporate credit unions Issues related to fixed assets Issues related to credit union conversions Issues related to credit union call report modernization Issues related to NCUA's Corporate Credit Union Stabilization Plan Issues related to NCUA's budget and the overhead transfer rate Issues related to Credit Union Service Organizations (CUSO) Issues related to the authority of the CFPB to exempt credit unions from its rulemaking Issues related to the CFPB rule to remittances and international wire transfers Issues related to CFPB's Leadership structure and Installing a Board rather than a Director Issues related to codifying the CFPB's Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to overdraft protection and check ordering practices Issues related to mortgage servicing Issues related to mortgage loan originator compensation and qualifications Issues related to the CFPB's rule regarding qualified mortgage / ability to repay Issues related to the CFPB's regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the CFPB's regulation on Truth-In-Lending Act / Real Estate Settlement Procedures Act Integrated Disclosures Issues related to the payday, vehicle title, and similar lending Issues related to short term lending products and advance deposit products Issues related to the CFPB's consumer complaint database Issues related to the CFPB's consumer complaint database Issues related to the Department of Justice's investigation entitled, "Operation Choke Point" Issues related to indirect auto lending Issues related to credit union service to unbanked and underbanked consumers Issues related to the Financial Accounting Standards Board (FASB) Issues related to data and cyber security Issues related to mobile banking and mobile payments Issues related to identity theft and fraud reduction Issues related to secure payments Issues related to merchant data breaches Issues related to the payments system and innovation Issues related to the Fed's implementation of same-day ACH Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements Issues related to the oversight of the Federal Housing Administration Issues related to the USDA Rural Development Loan Program Issues related to the Federal Home Loan Bank System Issues related to membership eligibility in the Federal Home Loan Bank System Issues related to financial literacy Issues related to Housing Finance Reform Issues related to student lending Issues related to the Economic Growth and Regulatory Paperwork Reduction Act Process Issues related to retirement security Issues related to flood insurance Issues related to consumer's access to records Issues related to Interchange Fees Issues related to the Equal Credit Opportunity Act Issues related to the Fair Housing Act Issues related to the merger of credit unions Issues related to the Real Estate Settlement Procedures Act Issues related to Community Reinvestment Act Issues related to Regulation Z Issues related to Military Lending Act Issues related to Financial Technology Issues related to Small Business Lending Data Collection requirements Issues related to Involuntary liquidation of Federal Credit Unions and Claims Procedures Issues related to Web-Bases Quantitative Testing of Point of Sale / ATM Overdraft Disclosure Forms Issues related to residential appraisals Issues related to FHA appraisal certification Issues related to FHA and USDA Loan Modifications Issues related to Faster Payments Issues related to the Fair Credit Reporting Act Issues related to cooperative funding sources in federal appropriations legislation Issues related to regulation of debt collection activity Issues related to capital reform for credit unions Issues related to diversity and inclusion in Financial Services Issues related to Section 124 of the Federal Credit Union Act Issues related to the Consumer Financial Protection Bureau's No-Action Letters and the BCFP Product Sandbox Issues related to enterprise validation and approval of credit score models Issues related to the availability of Funds and Collection of Checks (Regulation CC) Issues related to arbitration clauses Issues related to SBA 7(a) loan program Issues related to financial institutions operating on military installations Issues related to postal banking Issues related to Telephone Consumer Protection Act Issues related to financial technology (FINTECH) Issues related to robocalls and the draft Declatory Ruling (the ruling) and Third Further Notice of Proposted Rulemaking (FNPRM) CG Docket No 17-59, WC Docket No. 17 - 97 Issues related to payday and small dollar lending Issues related to leases of non-excess property on military bases Issues related to Opportunity Zones Issues related to minority homeownership Issues related to the ability of Federal Credit unions to establish their own fiscal year Issues related to a requirement that Federal credit unions file certain information regarding loan officers Issues related to enhancing flexibility of Federal Credit Unions to schedule board meetings Issues related to removing certain outdated responsibilites of Federal credit union board of directors Issues related to permitting Federal credit unions to expel disruptive members for just cause without a vote Issues related to permitting balloting for conversions from state to federal charter and from federal to state charter to be conducted electronically Issues related to PACE Loans Issues related to minority depository insitutions Issues related to AI and cloud computing Issues related to the Consumer Online Privacy Rights Act Issues related to COVID-19 crisis response legislation Issues related to the Paycheck Protection Program Issues related to Taxi Medallion loans Issues related to QRM Risk Retection Review Issues related to NCUA's proposed rule on combination transactions Issues related to the regulation of credit unions as employers Issues related to liability protections for businesses Issues related to remote notary Issues related to digital identity legislation Issues related Paid Leave Payroll Tax Credits Issues related to Economic Impact Payments Issues related to Fed Accounts Issues related to the Federal Reserve's Main Street Lending Program Issues related to troubled debt restructuring Issues related to Prompt Corective Action requirements Issues related to NCUA subordinated debt rulemaking Issues related to Uniform Residential Loan Application Issues related to digitalization of money Issues related to electronic signatures on wire transfer documents Issues related to cybercriminal activity during COVID-19 Issues related to lender forebearance Issues related to Paycheck Protection Program forgiveness process Issues related to Agriculture Lending Issues related to OCC payment charters Issues related to the Student Empowerment and Financial Literacy Act Issues related to OCC National Bank and Savings Association Digital Activities Issues related to the treatment of certain COVID-19 Loss Mitigation options under RESPA (Reg X) Issues related to premium assessments by the National Credit Union Share Insurance Issues related to the proposed exclusion of PPP Loans from financial institution asset calculations Issues related to Section 4013 of the CARES Act Issues related to Section 4016 of the CARES Act Issues related tot he oversight of prudential regulators Issues related to PAL 1 Program Issues related to credit union asset size thresholds for regulatory compliance Issues related to NCUA MERIT examination system Issues related to NCUA Derivatives rulemaking Issues related to mortgage servicer assistance Issues related to Section 4022 of the CARES Act Issues related to the ability of NCUA to offer forbearance from Prompt Corrective Action Requirements Issues related to Temporarily Excluding Certain Low-Risk Assets from the Credit Union Net Worth Ratio Issues related to London Inter-Bank Offered Rate (LIBOR) Issues related to the regulation of Federal Employment Laws Issues related to the Office of Comptroller Charter Issues related to the Crypto Charter Issues related to the Solar Winds Data Breach Issues related to PPP Loan Necessity Questionnaires Issues related to SBA Economic Injury Disaster Loan Advances Issues related to Seasoned QM Loan Definitions Issues related to FHFA Strategic Plan for 2021-2024 Issues related to GSE Housing Goals Issues related to Member Business Lending Issues related to interest rate caps Issues related to Federal Housing Finance Agency's (FHFA) recapitalization plans Issues related to rental and mortgage payment assistance Issues related to BSA / AML Regulation Issues related to CECL Accounting requirements Issues related to climate control issues and effect on financial institutions Issues related to UDAAP guidance and requirements Issues related to risk-based capital requirements Issues related to NCUA's Communications and Transparency Issues related to Enterprise liquidity framework (FHFA) Issues related to the discussion draft of the Expanding Financial Access for Underserved Communities Act Issues related to the NCUA's Capitalization of Interest in Connection with Loan Workouts and Modifications Rulemaking Issues related to the Federal Reserve's proposed Regulation II Issues related to Capitalizing interest on consumer loans Issues related to Cryptocurrency Issues related to proposed postal banking pilot program Issues related to proposed new tax reporting requirements for financial institutions Issues related to the implementation of consumer financial protection laws Issues related to the safety and soundness regulations of credit unions Issues related to investment authority Issues related to BSA / AML regulation and Cannabis Banking Issues related to rate cap legislation and the Military Lending Act Issues related to credit card interchange fees and routing Issues related to FY22 National Defense Authorization Act Issues related to NCUA Central Liquidity Facility Issues related to Climate and Natural disaster risk management at regulated entities Issues related to PSPA / QM Conflict Issues related to CAMELS proposal Issues related to credit union coverage under GNMA rules Issues related to Cryptocurrency and digital assets Issues related to the re-nomination of Todd Harper to the NCUA Board Issues related to examining frameworks to address future pandemic risk Issues related to the NDAA rate cap proposals Issues related to the collection of checks and other items by Federal Reserve Banks and Funds Transfers through Fedwire Issues related to the potential modifications to the Federal Reserve policy on payment system risk Issues related to Small Business Bankruptcy Issues related to mortgage-backed securities insurance Issues related to the state of the rural economy Issues related to financial barriers to minority and women-owned businesses' involvement in infrastructure projects Issues related to the President's working group on financial market's report on stablecoins Issues related to economic impact of growing burden of medical debt Issues related to the Credit Union Employee and Member Safety Act in the FY2022 Omnibus Appropriations Act Issues related to the Interagency Task Force on Property Appraisal and Valuation Equity (PAVE) appraisals Issues related to the National Defense Authorization Act FY2023 Issues related to the Administration of the CDFI Fund Issues related to Central Bank Digital Currency Issues related to National Flood Insurance Program Reauthorization Issues related to Reg. II, Dodd Frank, Durbin Amendment, Section 107531 Issues related to G20 Rome Leaders Declaration Issues related to the United States Innovation and Competition Act of 2021 Issues related to Prompt Corrective Action: Earnings Retention Waivers and Net Worth Restoration Plans Issues related to Prohibition on Inclusion of Adverse Information in Consumer Reporting in Cases of Human Trafficking Issues related to the Truth in Savings Act (TISA) and Part 707 of the NCUA Rules and Regulations Issues related to 40 Year Term Loan Modifications H.J. Res 35, providing for Congressional disapproval under Chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders" S.J. Res 15, a joint resolution providing for congressional disapproval under Chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders" H.R. 133, the Consolidated Appropriations Act (2020) H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1395, the Housing Financial Literacy Act of 2021 H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act 0f 2021 H.R. 1996, Secure and Fair Enforcement (SAFE) Banking Act of 2021 H.R. 2040, the Financial Reporting Threshold Modernization Act H.R. 2311, To amend the Federal Credit Union Act to modernize certain processes regarding expulsion of credit union members for cause, and for other purposes H.R. 2471, the Consolidated Appropriations Act of 2022 H.R. 2547, the Comprehensive Debt Collection Improvement Act H.R. 3684, Infrastructure Investment and Jobs Act, Sec. 90005, Extension of enterprise guarantee fees H.R. 3958, Central Liquidity Facility Enhancement Act H.R. 3962, SECURE Notarization Act of 2021 H.R. 4495, the Downpayment Toward Equity Act of 2021 H.R. 4773, the Consumer Financial Protection Commission Act H.R. 4905, Promoting New and Diverse Depository Institutions Act H.R. 5189, Member Business Loan Expansion Act H.R. 5206, Tax Gap Reform and IRS Enforcement Act H.R. 5305, Extending Government Funding and Delivering Emergency Assistance Act H.R. 5451, Protecting Financial Privacy Act of 2021 H.R. 5912, the Close the ILC Loophole Act H.R. 6889, Credit Union Board Modernization Act H.R. 7003, Expanding Financial Access to Underserved Communities Act H.R. 8152, American Data Privacy and Protection Act S. 254, A bill to establish a Homeowner Assistance Fund at the Department of the Treasury S. 337, Stop Senior Scams Act S. 762, A bill to provide the National Credit Union Administration Board flexibility to increase Federal credit union loan maturities, and for other purposes S. 910, SAFE Banking Act of 2021 S. 1368, American Housing and Economic Mobility Act of 2021 S. 1625, Securing and Enabling Commerce Using Remote and Electronic Notarization Act S. 1767, the Credit Union Employee and Member Safety Act of 2021 S. 2857, Protection Financial Privacy Act of 2021 S. 3715, E-SIGN Modernization Act of 2022 S. 3813, Veterans Member Business Loan Act S. 4325, Credit Union Board Modernization S. 4356, The Responsible Financial Innovation Act
Client expense: $1,030,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA), Treasury, Dept of, Veterans Affairs, Dept of (VA)
2022 · second_quarter · Financial Institutions/Investments/Securities
Federal policy relating to anticipated Consumer Financial Protection Bureau regulation of consumer financial services including payday lending, auto title lending, and regulatory process. Potential legislation to regulate interest rates on financial products. S.J. Res. 15 - A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders." Implementation of the CARES Act (PL 116-136), provisions relating to the payroll protection program. Implementation of the American Rescue Plan Act of 2021 (PL-117-2), provisions relating to the payroll protection program. Legislative proposals relating to prohibiting retail businesses from refusing cash payments. H.R. 2040, The Financial Reporting Threshold Modernization Act, provisions relating to updating thresholds for certain currency transaction reports and suspicious activity reports. H.R. 1996, The SAFE Banking Act of 2021, provisions relating to the provision of financial services to cannabis-related businesses and service providers S. 563, The Fair Access to Banking Act, provisions relating to fair access to financial services and discount window lending programs. Veterans and Consumers Fair Credit Act (H.R. 5974/S. 2508), provisions relating to regulation of interest rates on financial products.
Client expense: Not reported · Firm income: $50,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2022 · second_quarter · Banking
Cryptocurrency, mobile payments, fraud, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy, the Federal Reserve and big data, CFPB prepaid products rule (Prepaid Accounts Under Direct Electronic Transfer Act {Regulation E} and the Truth in Lending Act), Federal Reserve Secure Payments Task Force, Marketplace lending, H.R. 10- Financial Choice Act of 2017, H.J. Res. 62/72-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 prepaid accounts under the Electronic Fund Transfer Act and the Truth in Lending Act, S.J.Res.19 - A joint resolution 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 prepaid accounts under the Electronic Fund Transfer Act and the Truth in Lending Act, H. R. 1801-To delay the effective date of the final rule of the Bureau of Consumer Financial Protection titled Prepaid Accounts under the Electronic Fund Transfer Act (Regulation E) and the Truth In Lending Act (Regulation Z)", S. 387-Consumer Financial Protection Bureau Accountability Act of 2017, S. 626-CFPB-IG Act of 2017. CFPB Governance Structure. H.J.Res. 111, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements." S.J.Res. 47, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements". H.R. 4439, Modernizing Credit Opportunities Act of 2017. H.R. 3299, Protecting Consumers' Access to Credit Act of 2017. S. 1642, Protecting Consumers' Access to Credit Act of 2017. H.R. 3354, Make America Secure & Prosperous Appropriations Act. H.R. 6743, Consumer Information Notification Requirement Act. H.R. 6850, Financial Reporting Threshold Modernization Act. "Potential Federal Reserve Actions To Support Interbank Settlement of Faster Payments, Request for Comments" (Docket # OP-1625). OCC ANPR "Reforming the Community Reinvestment Act Regulatory Framework" (Docket # OCC-2018- 0008). H.R. 1595, "SAFE Banking Act of 2019". FDIC Request for Information on Small-Dollar Lending (Docket No. RIN 3064-ZA04). S. 1200, Secure And Fair Enforcement Banking Act of 2019. H.R. 4813, Keep Big Tech Out of Finance Act. S. 2839, Eliminating Corporate Shadow Banking Act of 2019. S. 1951, Designing Accounting Safeguards To Help Broaden Oversight and Regulations on Data. H.R. 5574, "Preserving Small Business Lending Act of 2020." H.R. 6116, "Consumer Financial Protection Commission Act." S. 3548, "CARES Act." H.R. 6379, "Take Responsibility for Workers and Families Act." H.R. 748, "CARES Act." S. 3990, "Financial Product Safety Commission Act of 2020." H.R. 6886, "Paycheck Protection Program Flexibility Act of 2020." H.R. 710, "Paycheck Protection Program Flexibility Act of 2020." S.4116, "Bill to extend Paycheck Protection Program..." H.R. 8087, "Bill to extend Paycheck Protection Program..." H.R. 7777, "Paycheck Protection Small Business Forgiveness Act." H.R. 8265, "To amend the Small Business Act and the CARES Act to establish a program for second draw loans and make other modifications to the paycheck protection program and for other purposes..." S. 4614, "Postal Banking Act." H.R. 8406, "HEROS Act." H.R. 7889, "Small Business Lending Disclosure and Broker Regulation Act of 2020." OCC "True Lender." OCC "National Bank and Federal Savings Association Digital Activities." H.R. 8215, "Improving Digital Identity Act of 2020." U.S. House Committee on Financial Services' Task Force on Financial Technology and Task Force on Artificial Intelligence. S. 4999, "Emergency Direct Payments for Families and Workers Act of 2020." H.R. 8893, "Coronavirus Assistance for Americans Families Act." S. 4927, EIDL Forgiveness Act." H.R. 8827, "Stablecoin Classification and Regulation Act of 2020." S. 4800, "The Heroes Act." H.R. 8721, "Public Banking Act of 2020." S.J. Res 15, "True Lender." H.J. Res 35, "True Lender." H.R. 296, "Financial Technology Protection Act." H.R. 1602, "Eliminate Barriers to Innovation Act of 2021." H.R. 1996, "SAFE Banking Act of 2021." H.R. 2561, "Promoting Access to Capital in Underbanked Communities Act of 2021." H.R. 5045, "Blockchain Certainty Act." H.R. 4741, "Digital Asset Market Structure and Investor Protection Act," S. 3906, "Small Business Broadband and Emerging Information Technology Enhancement Act of 2022," S. 3970, "Stablecoin Transparency Act," H.R. 7231, "ECASH Act," H.R. 5912, "Close the ILC Loophole Act," S. 4356, "Responsible Financial Innovation Act," H.R. 7614, "Digital Commodity Exchange Act of 2022," S. 3970, "Stablecoin Transparency Act, "H.R. 3425, "Saving Gig Economy Taxpayers Act."
Client expense: $410,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Council of Economic Advisers (CEA), Federal Communications Commission (FCC), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Economic Council (NEC), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of, U.S. Trade Representative (USTR)
2022 · second_quarter · Financial Institutions/Investments/Securities
H.R. 1996 - SAFE Banking Act, S.J.Res15/H.J.Res35
Client expense: Not reported · Firm income: $45,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2022 · second_quarter · Financial Institutions/Investments/Securities
1. Basel Capital and Liquidity Treatment for asset-backed securities - General issues concerning the appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules (includes the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book, efforts to create "Simple, Transparent and Comparable" (STC) securitizations, STC treatment for short-term securitizations, and capital treatment of consolidated SPEs when risk transfer occurs). 2. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II for all ABS asset classes, specifically auto, credit card, equipment lease and student loans. 3. General Dodd-Frank Implementation and Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention, the Liquidity Coverage Ratio (LCR), and uncleared swap margin rules; issues related to risk retention provisions, the Volcker Rule (discussed SFA's recommended changes with staff at SEC, Federal Reserve Board, FDIC and OCC), arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; the implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018, specifically provisions potentially related to securitization. 4. SFA is a member of the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York working to determine best path for transition away from LIBOR (in 2021, the U.K.s Financial Conduct Authority will stop compelling banks to report LIBOR). SFA co-chairs the ARRCs Securitization Working Group which meets regularly with the goal of producing concrete recommendations on how best to effect the transition. 5. Advocacy related to industry concerns regarding the Bureaus proposed consent judgment in the case of Consumer Financial Protection Bureau v. National Collegiate Master Student Loan Trusts. This case has broad implications for the securitization market as the consent order could alter the parties settled contractual rights and obligations in these transactions. 6. Employee Retirement Income Security Act of 1974 (ERISA) - Issues relating to the interpretation and implementation of amendments and exemptions to ERISA as they relate to structured finance; issues related to ERISA disclosures provided in securitization offering documents. 7. Trust Indenture Act of 1939 (TIA) - Issues relating to a potential conflict with a provision of the Trust Indenture Act - allowing for a clarification to be limited to the LIBOR transition event and eliminating the potential of setting an unintended precedent. 8. True Lender - Issues relating to the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J. Res. 15. 9. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 10. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021, and its inclusion in the Consolidated Appropriations Act, 2022.
Client expense: $294,889 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2022 · second_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP) conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J. Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022.
Client expense: $294,889 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2022 · second_quarter · Financial Institutions/Investments/Securities
1. Basel Capital and Liquidity Treatment for asset-backed securities - General issues concerning the appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules (includes the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book, efforts to create "Simple, Transparent and Comparable" (STC) securitizations, STC treatment for short-term securitizations, and capital treatment of consolidated SPEs when risk transfer occurs). 2. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II for all ABS asset classes, specifically auto, credit card, equipment lease and student loans. 3. General Dodd-Frank Implementation and Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention, the Liquidity Coverage Ratio (LCR), and uncleared swap margin rules; issues related to risk retention provisions, the Volcker Rule (discussed SFA's recommended changes with staff at SEC, Federal Reserve Board, FDIC and OCC), arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; the implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018, specifically provisions potentially related to securitization. 4. SFA is a member of the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York working to determine best path for transition away from LIBOR (in 2021, the U.K.s Financial Conduct Authority will stop compelling banks to report LIBOR). SFA co-chairs the ARRCs Securitization Working Group which meets regularly with the goal of producing concrete recommendations on how best to effect the transition. 5. Advocacy related to industry concerns regarding the Bureaus proposed consent judgment in the case of Consumer Financial Protection Bureau v. National Collegiate Master Student Loan Trusts. This case has broad implications for the securitization market as the consent order could alter the parties settled contractual rights and obligations in these transactions. 6. Employee Retirement Income Security Act of 1974 (ERISA) - Issues relating to the interpretation and implementation of amendments and exemptions to ERISA as they relate to structured finance; issues related to ERISA disclosures provided in securitization offering documents. 7. Trust Indenture Act of 1939 (TIA) - Issues relating to a potential conflict with a provision of the Trust Indenture Act - allowing for a clarification to be limited to the LIBOR transition event and eliminating the potential of setting an unintended precedent. 8. True Lender - Issues relating to the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J. Res. 15. 9. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 10. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021, and its inclusion in the Consolidated Appropriations Act, 2022.
Client expense: $294,889 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2022 · second_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP) conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J. Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022.
Client expense: $294,889 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2022 · first_quarter · Banking
1. General issues concerning international efforts to establish "high-quality securitization" criteria. 2. Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP) conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J. Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022.
Client expense: $320,453 · Firm income: Not reported
Government targets: Federal Accounting Standards Advisory Board (FASAB), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2022 · first_quarter · Financial Institutions/Investments/Securities
1. Basel Capital and Liquidity Treatment for asset-backed securities - General issues concerning the appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules (includes the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book, efforts to create "Simple, Transparent and Comparable" (STC) securitizations, STC treatment for short-term securitizations, and capital treatment of consolidated SPEs when risk transfer occurs). 2. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II for all ABS asset classes, specifically auto, credit card, equipment lease and student loans. 3. General Dodd-Frank Implementation and Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention, the Liquidity Coverage Ratio (LCR), and uncleared swap margin rules; issues related to risk retention provisions, the Volcker Rule (discussed SFA's recommended changes with staff at SEC, Federal Reserve Board, FDIC and OCC), arbitration clauses, lead regulator concept, and "valid when made" loan provisions; reform proposals as they relate to securitization and capital markets generally; the implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018, specifically provisions potentially related to securitization. 4. SFA is a member of the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York working to determine best path for transition away from LIBOR (in 2021, the U.K.s Financial Conduct Authority will stop compelling banks to report LIBOR). SFA co-chairs the ARRCs Securitization Working Group which meets regularly with the goal of producing concrete recommendations on how best to effect the transition. 5. Advocacy related to industry concerns regarding the Bureaus proposed consent judgment in the case of Consumer Financial Protection Bureau v. National Collegiate Master Student Loan Trusts. This case has broad implications for the securitization market as the consent order could alter the parties settled contractual rights and obligations in these transactions. 6. Employee Retirement Income Security Act of 1974 (ERISA) - Issues relating to the interpretation and implementation of amendments and exemptions to ERISA as they relate to structured finance; issues related to ERISA disclosures provided in securitization offering documents. 7. Trust Indenture Act of 1939 (TIA) - Issues relating to a potential conflict with a provision of the Trust Indenture Act - allowing for a clarification to be limited to the LIBOR transition event and eliminating the potential of setting an unintended precedent. 8. True Lender - Issues relating to the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J. Res. 15. 9. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 10. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021, and its inclusion in the Consolidated Appropriations Act, 2022.
Client expense: $320,453 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of
2022 · first_quarter · Banking
Bank On Buy Now, Pay Later Central Bank Digital Currency Cryptocurrency Durbin Interchange Nominations USPS Pilot Banking Program H.R. 1996, The SAFE Banking Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2561, Promoting Access to Capital in Unbanked Communities Act of 2021 S. 910, SAFE Banking Act S.J.RES.15, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of Currency relating to "National Banks and Federal Savings Associations as Lenders." H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate LIBOR Act H.R. 5189, Member Business Loan Expansion Act S. 2508, Veterans and Consumer Fair Credit Act Perlmutter Amendment (H.Amdt.97) to H.R. 4350, National Defense Authorization Act of 2022 H.R. 2989, Financial Transparency Act H.R. 6145, Community Bank Relief Act of 2021 S. 3409, To amend the Economic Growth, Regulatory Relief, and Consumer Protection Act to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024. Emergency Capital Investment Issues for CDFI and MDI S. 3715, The E-SIGN Modernization Act Coin Circulation S. 3779, Adjustable Interest Rate LIBOR Act H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. H.R. 4277, Overdraft Protection Act of 2021 H.R 4521, America Competes Act of 2022 H.R.7003, Expanding Financial Access for Underserved Communities Act
Client expense: $1,666,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2022 · first_quarter · Banking
Cryptocurrency, mobile payments, fraud, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy, the Federal Reserve and big data, CFPB prepaid products rule (Prepaid Accounts Under Direct Electronic Transfer Act {Regulation E} and the Truth in Lending Act), Federal Reserve Secure Payments Task Force, Marketplace lending, H.R. 10- Financial Choice Act of 2017, H.J. Res. 62/72-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 prepaid accounts under the Electronic Fund Transfer Act and the Truth in Lending Act, S.J.Res.19 - A joint resolution 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 prepaid accounts under the Electronic Fund Transfer Act and the Truth in Lending Act, H. R. 1801-To delay the effective date of the final rule of the Bureau of Consumer Financial Protection titled Prepaid Accounts under the Electronic Fund Transfer Act (Regulation E) and the Truth In Lending Act (Regulation Z)", S. 387-Consumer Financial Protection Bureau Accountability Act of 2017, S. 626-CFPB-IG Act of 2017. CFPB Governance Structure. H.J.Res. 111, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements." S.J.Res. 47, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements". H.R. 4439, Modernizing Credit Opportunities Act of 2017. H.R. 3299, Protecting Consumers' Access to Credit Act of 2017. S. 1642, Protecting Consumers' Access to Credit Act of 2017. H.R. 3354, Make America Secure & Prosperous Appropriations Act. H.R. 6743, Consumer Information Notification Requirement Act. H.R. 6850, Financial Reporting Threshold Modernization Act. "Potential Federal Reserve Actions To Support Interbank Settlement of Faster Payments, Request for Comments" (Docket # OP-1625). OCC ANPR "Reforming the Community Reinvestment Act Regulatory Framework" (Docket # OCC-2018- 0008). H.R. 1595, "SAFE Banking Act of 2019". FDIC Request for Information on Small-Dollar Lending (Docket No. RIN 3064-ZA04). S. 1200, Secure And Fair Enforcement Banking Act of 2019. H.R. 4813, Keep Big Tech Out of Finance Act. S. 2839, Eliminating Corporate Shadow Banking Act of 2019. S. 1951, Designing Accounting Safeguards To Help Broaden Oversight and Regulations on Data. H.R. 5574, "Preserving Small Business Lending Act of 2020." H.R. 6116, "Consumer Financial Protection Commission Act." S. 3548, "CARES Act." H.R. 6379, "Take Responsibility for Workers and Families Act." H.R. 748, "CARES Act." S. 3990, "Financial Product Safety Commission Act of 2020." H.R. 6886, "Paycheck Protection Program Flexibility Act of 2020." H.R. 710, "Paycheck Protection Program Flexibility Act of 2020." S.4116, "Bill to extend Paycheck Protection Program..." H.R. 8087, "Bill to extend Paycheck Protection Program..." H.R. 7777, "Paycheck Protection Small Business Forgiveness Act." H.R. 8265, "To amend the Small Business Act and the CARES Act to establish a program for second draw loans and make other modifications to the paycheck protection program and for other purposes..." S. 4614, "Postal Banking Act." H.R. 8406, "HEROS Act." H.R. 7889, "Small Business Lending Disclosure and Broker Regulation Act of 2020." OCC "True Lender." OCC "National Bank and Federal Savings Association Digital Activities." H.R. 8215, "Improving Digital Identity Act of 2020." U.S. House Committee on Financial Services' Task Force on Financial Technology and Task Force on Artificial Intelligence. S. 4999, "Emergency Direct Payments for Families and Workers Act of 2020." H.R. 8893, "Coronavirus Assistance for Americans Families Act." S. 4927, EIDL Forgiveness Act." H.R. 8827, "Stablecoin Classification and Regulation Act of 2020." S. 4800, "The Heroes Act." H.R. 8721, "Public Banking Act of 2020." S.J. Res 15, "True Lender." H.J. Res 35, "True Lender." H.R. 296, "Financial Technology Protection Act." H.R. 1602, "Eliminate Barriers to Innovation Act of 2021." H.R. 1996, "SAFE Banking Act of 2021." H.R. 2561, "Promoting Access to Capital in Underbanked Communities Act of 2021." H.R. 5045, "Blockchain Certainty Act." H.R. 4741, "Digital Asset Market Structure and Investor Protection Act," S. 3906, "Small Business Broadband and Emerging Information Technology Enhancement Act of 2022," S. 3970, "Stablecoin Transparency Act," H.R. 7231, "ECASH Act."
Client expense: $410,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Council of Economic Advisers (CEA), Federal Communications Commission (FCC), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Economic Council (NEC), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of, U.S. Trade Representative (USTR)
2022 · first_quarter · Banking
Issues related to Federal Credit Union Charter Modernization Issues related to credit union operations Issues related to credit union field of membership Issues related to credit union service organization Issues related to NCUA's low income designation regulation Issues related to NCUA examination procedures Issues related to NCUA's regulation regarding liquidity Issues related to NCUA's rulemaking process Issues related to NCUA's regulatory review process Issues related to Federal Credit Union Bylaws Issues related to credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union By-Laws Issues related to credit unions' incidental powers Issues related to credit union service to marijuana businesses Issues related to material loss reports of the NCUA Office of Inspector General Issues related to the regulation of corporate credit unions Issues related to fixed assets Issues related to credit union conversions Issues related to credit union call report modernization Issues related to NCUA's Corporate Credit Union Stabilization Plan Issues related to NCUA's budget and the overhead transfer rate Issues related to Credit Union Service Organizations (CUSO) Issues related to the authority of the CFPB to exempt credit unions from its rulemaking Issues related to the CFPB rule to remittances and international wire transfers Issues related to CFPB's Leadership structure and Installing a Board rather than a Director Issues related to codifying the CFPB's Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to overdraft protection and check ordering practices Issues related to mortgage servicing Issues related to mortgage loan originator compensation and qualifications Issues related to the CFPB's rule regarding qualified mortgage / ability to repay Issues related to the CFPB's regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the CFPB's regulation on Truth-In-Lending Act / Real Estate Settlement Procedures Act Integrated Disclosures Issues related to the payday, vehicle title, and similar lending Issues related to short term lending products and advance deposit products Issues related to the CFPB's consumer complaint database Issues related to the CFPB's consumer complaint database Issues related to the Department of Justice's investigation entitled, "Operation Choke Point" Issues related to indirect auto lending Issues related to credit union service to unbanked and underbanked consumers Issues related to the Financial Accounting Standards Board (FASB) Issues related to data and cyber security Issues related to mobile banking and mobile payments Issues related to identity theft and fraud reduction Issues related to secure payments Issues related to merchant data breaches Issues related to the payments system and innovation Issues related to the Fed's implementation of same-day ACH Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements Issues related to the oversight of the Federal Housing Administration Issues related to the USDA Rural Development Loan Program Issues related to the Federal Home Loan Bank System Issues related to membership eligibility in the Federal Home Loan Bank System Issues related to financial literacy Issues related to Housing Finance Reform Issues related to student lending Issues related to the Economic Growth and Regulatory Paperwork Reduction Act Process Issues related to retirement security Issues related to flood insurance Issues related to consumer's access to records Issues related to Interchange Fees Issues related to the Equal Credit Opportunity Act Issues related to the Fair Housing Act Issues related to the merger of credit unions Issues related to the Real Estate Settlement Procedures Act Issues related to Community Reinvestment Act Issues related to Regulation Z Issues related to Military Lending Act Issues related to Financial Technology Issues related to Small Business Lending Data Collection requirements Issues related to Involuntary liquidation of Federal Credit Unions and Claims Procedures Issues related to Web-Bases Quantitative Testing of Point of Sale / ATM Overdraft Disclosure Forms Issues related to residential appraisals Issues related to FHA appraisal certification Issues related to FHA and USDA Loan Modifications Issues related to Faster Payments Issues related to the Fair Credit Reporting Act Issues related to cooperative funding sources in federal appropriations legislation Issues related to regulation of debt collection activity Issues related to capital reform for credit unions Issues related to diversity and inclusion in Financial Services Issues related to Section 124 of the Federal Credit Union Act Issues related to the Consumer Financial Protection Bureau's No-Action Letters and the BCFP Product Sandbox Issues related to enterprise validation and approval of credit score models Issues related to the availability of Funds and Collection of Checks (Regulation CC) Issues related to arbitration clauses Issues related to SBA 7(a) loan program Issues related to financial institutions operating on military installations Issues related to postal banking Issues related to Telephone Consumer Protection Act Issues related to financial technology (FINTECH) Issues related to robocalls and the draft Declatory Ruling (the ruling) and Third Further Notice of Proposted Rulemaking (FNPRM) CG Docket No 17-59, WC Docket No. 17 - 97 Issues related to payday and small dollar lending Issues related to leases of non-excess property on military bases Issues related to Opportunity Zones Issues related to minority homeownership Issues related to the ability of Federal Credit unions to establish their own fiscal year Issues related to a requirement that Federal credit unions file certain information regarding loan officers Issues related to enhancing flexibility of Federal Credit Unions to schedule board meetings Issues related to removing certain outdated responsibilites of Federal credit union board of directors Issues related to permitting Federal credit unions to expel disruptive members for just cause without a vote Issues related to permitting balloting for conversions from state to federal charter and from federal to state charter to be conducted electronically Issues related to PACE Loans Issues related to minority depository insitutions Issues related to AI and cloud computing Issues related to the Consumer Online Privacy Rights Act Issues related to COVID-19 crisis response legislation Issues related to the Paycheck Protection Program Issues related to Taxi Medallion loans Issues related to QRM Risk Retection Review Issues related to NCUA's proposed rule on combination transactions Issues related to the regulation of credit unions as employers Issues related to liability protections for businesses Issues related to remote notary Issues related to digital identity legislation Issues related Paid Leave Payroll Tax Credits Issues related to Economic Impact Payments Issues related to Fed Accounts Issues related to the Federal Reserve's Main Street Lending Program Issues related to troubled debt restructuring Issues related to Prompt Corective Action requirements Issues related to NCUA subordinated debt rulemaking Issues related to Uniform Residential Loan Application Issues related to digitalization of money Issues related to electronic signatures on wire transfer documents Issues related to cybercriminal activity during COVID-19 Issues related to lender forebearance Issues related to Paycheck Protection Program forgiveness process Issues related to Agriculture Lending Issues related to OCC payment charters Issues related to the Student Empowerment and Financial Literacy Act Issues related to OCC National Bank and Savings Association Digital Activities Issues related to the treatment of certain COVID-19 Loss Mitigation options under RESPA (Reg X) Issues related to premium assessments by the National Credit Union Share Insurance Issues related to the proposed exclusion of PPP Loans from financial institution asset calculations Issues related to Section 4013 of the CARES Act Issues related to Section 4016 of the CARES Act Issues related tot he oversight of prudential regulators Issues related to PAL 1 Program Issues related to credit union asset size thresholds for regulatory compliance Issues related to NCUA MERIT examination system Issues related to NCUA Derivatives rulemaking Issues related to mortgage servicer assistance Issues related to Section 4022 of the CARES Act Issues related to the ability of NCUA to offer forbearance from Prompt Corrective Action Requirements Issues related to Temporarily Excluding Certain Low-Risk Assets from the Credit Union Net Worth Ratio Issues related to London Inter-Bank Offered Rate (LIBOR) Issues related to the regulation of Federal Employment Laws Issues related to the Office of Comptroller Charter Issues related to the Crypto Charter Issues related to the Solar Winds Data Breach Issues related to PPP Loan Necessity Questionnaires Issues related to SBA Economic Injury Disaster Loan Advances Issues related to Seasoned QM Loan Definitions Issues related to FHFA Strategic Plan for 2021-2024 Issues related to GSE Housing Goals Issues related to Member Business Lending Issues related to interest rate caps Issues related to Federal Housing Finance Agency's (FHFA) recapitalization plans Issues related to rental and mortgage payment assistance Issues related to BSA / AML Regulation Issues related to CECL Accounting requirements Issues related to climate control issues and effect on financial institutions Issues related to UDAAP guidance and requirements Issues related to risk-based capital requirements Issues related to NCUA's Communications and Transparency Issues related to Enterprise liquidity framework (FHFA) Issues related to the discussion draft of the Expanding Financial Access for Underserved Communities Act Issues related to the NCUA's Capitalization of Interest in Connection with Loan Workouts and Modifications Rulemaking Issues related to the Federal Reserve's proposed Regulation II Issues related to Capitalizing interest on consumer loans Issues related to Cryptocurrency Issues related to proposed postal banking pilot program Issues related to proposed new tax reporting requirements for financial institutions Issues related to the implementation of consumer financial protection laws Issues related to the safety and soundness regulations of credit unions Issues related to investment authority Issues related to BSA / AML regulation and Cannabis Banking Issues related to rate cap legislation and the Military Lending Act Issues related to credit card interchange fees and routing Issues related to FY22 National Defense Authorization Act Issues related to NCUA Central Liquidity Facility Issues related to Climate and Natural disaster risk management at regulated entities Issues related to PSPA / QM Conflict Issues related to CAMELS proposal Issues related to credit union coverage under GNMA rules Issues related to Cryptocurrency and digital assets Issues related to the re-nomination of Todd Harper to the NCUA Board Issues related to examining frameworks to address future pandemic risk Issues related to the NDAA rate cap proposals Issues related to the collection of checks and other items by Federal Reserve Banks and Funds Transfers through Fedwire Issues related to the potential modifications to the Federal Reserve policy on payment system risk Issues related to Small Business Bankruptcy Issues related to mortgage-backed securities insurance Issues related to the state of the rural economy Issues related to financial barriers to minority and women-owned businesses' involvement in infrastructure projects Issues related to the President's working group on financial market's report on stablecoins Issues related to economic impact of growing burden of medical debt Issues related to the Credit Union Employee and Member Safety Act in the FY2022 Omnibus Appropriations Act Issues related to the Interagency Task Force on Property Appraisal and Valuation Equity (PAVE) appraisals H.J. Res 35, providing for Congressional disapproval under Chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders" S.J. Res 15, a joint resolution providing for congressional disapproval under Chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders" H.R. 133, the Consolidated Appropriations Act (2020) H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1395, the Housing Financial Literacy Act of 2021 H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act 0f 2021 H.R. 1996, Secure and Fair Enforcement (SAFE) Banking Act of 2021 H.R. 2040, the Financial Reporting Threshold Modernization Act H.R. 2311, To amend the Federal Credit Union Act to modernize certain processes regarding expulsion of credit union members for cause, and for other purposes H.R. 2471, the Consolidated Appropriations Act of 2022 H.R. 2547, the Comprehensive Debt Collection Improvement Act H.R. 3684, Infrastructure Investment and Jobs Act, Sec. 90005, Extension of enterprise guarantee fees H.R. 3958, Central Liquidity Facility Enhancement Act H.R. 3962, SECURE Notarization Act of 2021 H.R. 4773, the Consumer Financial Protection Commission Act H.R. 4905, Promoting New and Diverse Depository Institutions Act H.R. 5206, Tax Gap Reform and IRS Enforcement Act H.R. 5305, Extending Government Funding and Delivering Emergency Assistance Act H.R. 5451, Protecting Financial Privacy Act of 2021 H.R. 5189, Member Business Loan Expansion Act H.R. 6889, Credit Union Board Modernization Act H.R. 7003, Expanding Financial Access to Underserved Communities Act S. 254, A bill to establish a Homeowner Assistance Fund at the Department of the Treasury S. 337, Stop Senior Scams Act S. 762, A bill to provide the National Credit Union Administration Board flexibility to increase Federal credit union loan maturities, and for other purposes S. 910, SAFE Banking Act of 2021 S. 1368, American Housing and Economic Mobility Act of 2021 S. 1625, Securing and Enabling Commerce Using Remote and Electronic Notarization Act S. 1767, the Credit Union Employee and Member Safety Act of 2021 S. 2857, Protection Financial Privacy Act of 2021 S. 3715, E-SIGN Modernization Act of 2022 S. 3813, Veterans Member Business Loan Act
Client expense: $1,200,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA), Treasury, Dept of, Veterans Affairs, Dept of (VA)
2022 · first_quarter · Financial Institutions/Investments/Securities
H.R. 1996 - SAFE Banking Act, S.J.Res15/H.J.Res35
Client expense: Not reported · Firm income: $40,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE