ELIZABETH LABERGE

Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance; H.R. 133, the Consolidated Appropriations Act of 2021; support efforts to correct gaps in BSA/AML regulations and CVC reporting; urges FinCEN to allow for additional time for stakeholder comments and providing a reasonable implementation period for new requirements; support CDCs recommendation that workers in the finance industry be included as essential workers; support dedicated cash window to include all credit unions; support communication on relevant information regarding the First and Second Draw PPP loans; supports HUDs proposal to amend the FHAs regulations to allow borrowers of single-family properties and other insured properties the option to purchase private flood insurance on FHA-insured mortgages for properties located in Special Flood Hazard Areas (SFHAs) to satisfy the mandatory purchase requirements of the Flood Disaster Protection Act of 1973; support additional investment authorities for credit unions to manage this influx of deposits; support access to credit for small businesses impacted by the COVID-19; support loan maturity extension; FCU Act should allow all credit unions to add underserved areas to their fields of membership; support ESIGN Modernization; expand section 4016 of the CARES Act; parity for credit unions for protections under section 4008 of the CARES Act; expand section 4014 of the CARES Act; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; caution you against making major changes to bankruptcy law; NCUA should (1) immediately issue an interim final rule to provide credit unions parity with recent changes made to community bank threshold standards or offer a different evaluation of credit union assets; and (2) coordinate with the CFPB to provide uniformity in the calculation of credit union assets for purposes of the $10 billion threshold; support efforts to provide flexibility for FCUs to operate their mortgage loan businesses and provide FICUs with another avenue to sell their mortgage servicing rights; support proposed rule to remove the prohibition on the capitalization of interest under Appendix B to Part 741; support authorization of a second PPP loan, simplifying loan forgiveness for PPP loans under the $150,000 threshold and repealing the deduction of EIDL advances from the PPP loan forgiveness amount; Consumer Access to Financial Records; RIN: 3170-AA78; avoid implementing section 1033 in a way that impairs a credit unions ability to protect its members data from the risk of theft or abuse; support update to Chartering and Field of Membership and Shared Facility Requirements, support modernization of the Manual by including online and mobile banking platforms in the definition of service facility; Exempt credit unions from the CECL standard; support proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy; urge the SBA to reduce loan forgiveness review times, focus reviews on larger and riskier loans, and provide consistent processing; opposes any premium that is the direct result of excess share growth rather than material weakness in the Share insurance fund because year-end financials of the SIF reflect the overall strength of the fund; support targeted efforts to help small businesses in these trying times, especially minority- and women-owned businesses that have struggled to access funding; support Homeowner Assistance Fund bill; Ensure that there is a liability shield for businesses that follow the law, protect their employees; raise concerns about legislatively mandated blanket loan forbearance; supports the NCUA having express authority to exempt federally-insured credit unions (FICUs) from suspicious activity report (SAR) requirements; support the FHFAs acknowledgement of the need to modernize appraisals by creating a more streamlined and accurate valuation process, requests that the FHFA require consistent practices among individual appraisers; continue to allow Automated Valuation Models (AVMs) and appraisal waivers to be used for all low-risk mortgage loans; and update the AVM technology to allow AVMs to be used in rural areas to improve appraisal turnaround times; H.R. 1319, the American Rescue Plan Act of 2021; Provide temporary capital flexibility for the National Credit Union Administration (NCUA) and credit unions, such as a reduction in the level at which credit unions are considered well capitalized; Urges Support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; support relief from the member business loan (MBL) cap; requests that the NCUA consolidate its supervisory guidance into fewer letterheads, improve its website to increase usability, and release timely cybersecurity risk alerts; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; support allowing the GSEs to rebuild capital and ensuring the GSEs are in a safe and sound financial condition before exiting conservatorship to guarantee a healthy and sustainable secondary mortgage market; ensure that any incentives for excessive risk-taking are eliminated but the FHFA should be encouraging the GSEs to focus on increasing opportunities for very-low, low-, and moderate income individuals to purchase a home; support Economic Aid to Hard-Hit Small Businesses, Nonprofits and Venues Act (Economic Aid Act) as part of the year-end stimulus package; support expansion for SBA Interim Final Rule that implements a revised PPP loan calculation formula for Schedule C filers; reject and urge against pilot program for USPS postal banking; support American Rescue Plan Act assistance; exclude credit union member business loans made in response to COVID-19 relief from the credit union member business lending (MBL) cap; urge the Bureau to initiate a rulemaking and exercise its supervisory authority over fintech companies that fall within the scope of a larger participant in the consumer financial services market; urge CFPB to coordinate with the FHFA as it examines its authority to regulate and supervise non-bank mortgage companies; Risk-Based Net Worth-COVID-19 Regulatory Relief; reject ICBAs ongoing attacks on the credit unions; support bank-credit union mergers.

Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance; H.R. 133, the Consolidated Appropriations Act of 2021; support efforts to correct gaps in BSA/AML regulations and CVC reporting; urges FinCEN to allow for additional time for stakeholder comments and providing a reasonable implementation period for new requirements; support CDCs recommendation that workers in the finance industry be included as essential workers; support dedicated cash window to include all credit unions; support communication on relevant information regarding the First and Second Draw PPP loans; supports HUDs proposal to amend the FHAs regulations to allow borrowers of single-family properties and other insured properties the option to purchase private flood insurance on FHA-insured mortgages for properties located in Special Flood Hazard Areas (SFHAs) to satisfy the mandatory purchase requirements of the Flood Disaster Protection Act of 1973; support additional investment authorities for credit unions to manage this influx of deposits; support access to credit for small businesses impacted by the COVID-19; support loan maturity extension; FCU Act should allow all credit unions to add underserved areas to their fields of membership; support ESIGN Modernization; expand section 4016 of the CARES Act; parity for credit unions for protections under section 4008 of the CARES Act; expand section 4014 of the CARES Act; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; caution you against making major changes to bankruptcy law; NCUA should (1) immediately issue an interim final rule to provide credit unions parity with recent changes made to community bank threshold standards or offer a different evaluation of credit union assets; and (2) coordinate with the CFPB to provide uniformity in the calculation of credit union assets for purposes of the $10 billion threshold; support efforts to provide flexibility for FCUs to operate their mortgage loan businesses and provide FICUs with another avenue to sell their mortgage servicing rights; support proposed rule to remove the prohibition on the capitalization of interest under Appendix B to Part 741; support authorization of a second PPP loan, simplifying loan forgiveness for PPP loans under the $150,000 threshold and repealing the deduction of EIDL advances from the PPP loan forgiveness amount; Consumer Access to Financial Records; RIN: 3170-AA78; avoid implementing section 1033 in a way that impairs a credit unions ability to protect its members data from the risk of theft or abuse; support update to Chartering and Field of Membership and Shared Facility Requirements, support modernization of the Manual by including online and mobile banking platforms in the definition of service facility; Exempt credit unions from the CECL standard; support proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy; urge the SBA to reduce loan forgiveness review times, focus reviews on larger and riskier loans, and provide consistent processing; opposes any premium that is the direct result of excess share growth rather than material weakness in the Share insurance fund because year-end financials of the SIF reflect the overall strength of the fund; support targeted efforts to help small businesses in these trying times, especially minority- and women-owned businesses that have struggled to access funding; support Homeowner Assistance Fund bill; Ensure that there is a liability shield for businesses that follow the law, protect their employees; raise concerns about legislatively mandated blanket loan forbearance; supports the NCUA having express authority to exempt federally-insured credit unions (FICUs) from suspicious activity report (SAR) requirements; support the FHFAs acknowledgement of the need to modernize appraisals by creating a more streamlined and accurate valuation process, requests that the FHFA require consistent practices among individual appraisers; continue to allow Automated Valuation Models (AVMs) and appraisal waivers to be used for all low-risk mortgage loans; and update the AVM technology to allow AVMs to be used in rural areas to improve appraisal turnaround times; H.R. 1319, the American Rescue Plan Act of 2021; Provide temporary capital flexibility for the National Credit Union Administration (NCUA) and credit unions, such as a reduction in the level at which credit unions are considered well capitalized; Urges Support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; support relief from the member business loan (MBL) cap; requests that the NCUA consolidate its supervisory guidance into fewer letterheads, improve its website to increase usability, and release timely cybersecurity risk alerts; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; support allowing the GSEs to rebuild capital and ensuring the GSEs are in a safe and sound financial condition before exiting conservatorship to guarantee a healthy and sustainable secondary mortgage market; ensure that any incentives for excessive risk-taking are eliminated but the FHFA should be encouraging the GSEs to focus on increasing opportunities for very-low, low-, and moderate income individuals to purchase a home; support Economic Aid to Hard-Hit Small Businesses, Nonprofits and Venues Act (Economic Aid Act) as part of the year-end stimulus package; support expansion for SBA Interim Final Rule that implements a revised PPP loan calculation formula for Schedule C filers; reject and urge against pilot program for USPS postal banking; support American Rescue Plan Act assistance; exclude credit union member business loans made in response to COVID-19 relief from the credit union member business lending (MBL) cap; urge the Bureau to initiate a rulemaking and exercise its supervisory authority over fintech companies that fall within the scope of a larger participant in the consumer financial services market; urge CFPB to coordinate with the FHFA as it examines its authority to regulate and supervise non-bank mortgage companies; Risk-Based Net Worth-COVID-19 Regulatory Relief; reject ICBAs ongoing attacks on the credit unions; support bank-credit union mergers.

Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; Overhead Transfer Rate (OTR) methodology and operating fee schedule; support of the FCC's efforts to establish and implement exemptions to the TCPAs consent requirement for important information about fraudulent activity, data breaches and available protections, and money transfers; supportive of the FCCs proposal to not limit the number of calls made under the exemption; Comment on Annual Certification and Data Collection Report Form (ACR) and the Certification Transaction Level Report (CTLR), concerned about the reporting burden and cybersecurity risks associated with the proposed ACR and CTRL; support the certainty and regulatory flexibility afforded by many of the new and updated Interagency Questions and Answers regarding flood insurance; express concern the proposed Community Development Financial Institutions Program application creates many such barriers, which ultimately will make it more difficult and unlikely that credit unions will obtain and maintain CDFI-designation; urge the Federal Housing Finance Agency (FHFA) to evaluate top credit union regulatory priorities, Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the National Credit Union Administration (NCUA) to evaluate the priority issues and enact the requested policy modifications re: Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the U.S. Department of the Treasury (Treasury) along with the Financial Crimes Enforcement Network (FinCEN) and the Internal Revenue Service (IRS) to evaluate the top credit union priorities; express concern with Section 2885 of S.4049, which would expand access to nominal leases on military installations for banks; support for Division F, the Corporate Transparency Act of 2019 and Division G, the COUNTER Act of 2019, of H.R.6395, which would make critical improvements to our Bank Secrecy Act (BSA)/anti-money laundering (AML)/beneficial ownership regime; support of a simplified loan forgiveness process for PPP loans under a $150,000 threshold, such as proposed in H.R.7777/S.4117, the Paycheck Protection Small Business Forgiveness Act; support a second round of PPP loans to the hardest hit small businesses; extend the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) that were enacted in section 4016 of the CARES Act and to extend the provisions from section 4013 of the CARES Act dealing with Troubled Debt Restructuring (TDR); support H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020; support excluding EIDL advances from the PPP forgiveness calculation, as proposed by bipartisan legislation in the House, HR.8361, the EIDL Forgiveness Act; supports legislation, H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020, which would provide temporary relief from the credit union member business lending (MBL) cap; support increase funding for the CDFI and CDRLF programs. Providing $1 billion in emergency funding for the CDFI Fund would allow more credit unions to access monies for specific programs; support the Health and Economic Recovery Omnibus Emergency Solutions Act (HEROES Act); support the inclusion of S.4159, the E-SIGN Modernization Act of 2020, in the relief package; credit unions, as not-for-profit cooperative institutions, should not be subject to the CECL standard; support a reduction in the level at which credit unions are considered well capitalized from a net-worth ratio of seven percent to six percent and adequately capitalized from six percent to five percent during the pandemic; reject any idea, even if well-meaning, that could place new hardships on credit unions; urges the Bureau of Consumer Financial Protection (Bureau or CFPB) to evaluate top credit union priorities, Delay Section 1071 Rulemaking, Electronic Disclosure Relief and Credit Card Accountability Responsibility and Disclosure Act of 2009 Act (CARD Act) Improvements, Temporarily Halt the Qualified Mortgage (QM) Rulemaking, Revise Home Mortgage Disclosure Act (HMDA) Rule and Reporting, Facilitate the London Interbank Offered Rate (LIBOR) Transition, Unfair, Deceptive, or Abusive Acts and Practices (UDAAP) Guidance and Rulemaking; urge NCUA provide relief to credit unions as they serve their members during the pandemic: Expanding Virtual Meetings, Managing Unexpected Share Growth, Additional Investment Opportunities, Capitalizing Interest on Loan Modifications, Adopting Broader Capital Reform, Finalizing an Efficient and Measured Budget; supports FinCEN defining an overall effective and reasonably designed AML program, including the explicit requirement for a risk-assessment; support automatic loan forgiveness for PPP loans under $150,000 and support any legislative efforts; support legislative efforts to amend the CARES Act to exclude Economic Injury Disaster Loans (EIDL) advance amounts from the calculation of loan forgiveness under the PPP; support initial 3508EZ form and the newly created 3508S form for loans under $50,000; support H.R. 8361, the EIDL Forgiveness Act; recommend a comment period of 90 days for all novel charter applications including the recent filings by Figure Bank for a national charter and Anchorage for a trust charter; TRACED Act; urged the Commission (FCC) not to impose additional restrictions on the existing exemption for informational calls placed to residential telephone numbers (Informational Calls Exemption); urges FinCEN to retain the current Recordkeeping and Travel Rule thresholds; supports the definition of money as proposed, which will resolve ambiguities surrounding applicability to convertible virtual currencies (CVCs); Thresholds for the Requirement to Collect, Retain, and Transmit Information Under the Recordkeeping and Travel Rules (Docket No.: FINCEN-2020-0002; RIN No.: 1506-AB41); Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support increase in size standards for North American Industry Classification System (NAICS) sectors related to finance and insurance, specifically NAICS code 522130 for credit unions; inclusion of S.4117, the Paycheck Protection Small Business Forgiveness Act; support the extensions of the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) and Troubled Debt Restructuring (TDR) provisions from the CARES Act; support focused clarification of regulatory expectations re: ECOA and Reg B; support HUDs codifying court rulings for disparate impact; support extension of CARES Act provisions: Section 1102: Paycheck Protection Program, Section 4012: Community Bank Leverage Ratio, Section 4014: Current Expected Credit Loss (CECL), Section 4008: Deposit Insurance, Section 4013: Troubled Debt Restructuring (TDR), Section 4016: NCUAs Central Liquidity Facility (CLF), Section 1110: Economic Injury Disaster Loan (EIDL) Program; Conference Report for H.R. 6395, the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021; express concern re: The Senates version of the FY 2021 NDAA, S.4049; supports efforts to provide additional emergency funding for CDFIs; outlines several recommendations to improve the efficiency of NCUA budget; bipartisan beneficial ownership and BSA/AML reform legislation - the Corporate Transparency Act and the COUNTER Act; Notice of Ex Parte Presentations, Rules & Regulations Implementing the Tel. Consumer Prot. Act of 1991, CG Docket No. 02-278; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support $25 billion in rental assistance to the Treasury Department to allocate to state and local governments, as well as extends the eviction moratorium; support NCUA modernizing the agencys derivatives rule, changing from a prescriptive approach to a more flexible, principles-based approach; support appreciates the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance ; H.R. 133, the Consolidated Appropriations Act of 2021

Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; Overhead Transfer Rate (OTR) methodology and operating fee schedule; support of the FCC's efforts to establish and implement exemptions to the TCPAs consent requirement for important information about fraudulent activity, data breaches and available protections, and money transfers; supportive of the FCCs proposal to not limit the number of calls made under the exemption; Comment on Annual Certification and Data Collection Report Form (ACR) and the Certification Transaction Level Report (CTLR), concerned about the reporting burden and cybersecurity risks associated with the proposed ACR and CTRL; support the certainty and regulatory flexibility afforded by many of the new and updated Interagency Questions and Answers regarding flood insurance; express concern the proposed Community Development Financial Institutions Program application creates many such barriers, which ultimately will make it more difficult and unlikely that credit unions will obtain and maintain CDFI-designation; urge the Federal Housing Finance Agency (FHFA) to evaluate top credit union regulatory priorities, Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the National Credit Union Administration (NCUA) to evaluate the priority issues and enact the requested policy modifications re: Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the U.S. Department of the Treasury (Treasury) along with the Financial Crimes Enforcement Network (FinCEN) and the Internal Revenue Service (IRS) to evaluate the top credit union priorities; express concern with Section 2885 of S.4049, which would expand access to nominal leases on military installations for banks; support for Division F, the Corporate Transparency Act of 2019 and Division G, the COUNTER Act of 2019, of H.R.6395, which would make critical improvements to our Bank Secrecy Act (BSA)/anti-money laundering (AML)/beneficial ownership regime; support of a simplified loan forgiveness process for PPP loans under a $150,000 threshold, such as proposed in H.R.7777/S.4117, the Paycheck Protection Small Business Forgiveness Act; support a second round of PPP loans to the hardest hit small businesses; extend the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) that were enacted in section 4016 of the CARES Act and to extend the provisions from section 4013 of the CARES Act dealing with Troubled Debt Restructuring (TDR); support H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020; support excluding EIDL advances from the PPP forgiveness calculation, as proposed by bipartisan legislation in the House, HR.8361, the EIDL Forgiveness Act; supports legislation, H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020, which would provide temporary relief from the credit union member business lending (MBL) cap; support increase funding for the CDFI and CDRLF programs. Providing $1 billion in emergency funding for the CDFI Fund would allow more credit unions to access monies for specific programs; support the Health and Economic Recovery Omnibus Emergency Solutions Act (HEROES Act); support the inclusion of S.4159, the E-SIGN Modernization Act of 2020, in the relief package; credit unions, as not-for-profit cooperative institutions, should not be subject to the CECL standard; support a reduction in the level at which credit unions are considered well capitalized from a net-worth ratio of seven percent to six percent and adequately capitalized from six percent to five percent during the pandemic; reject any idea, even if well-meaning, that could place new hardships on credit unions; urges the Bureau of Consumer Financial Protection (Bureau or CFPB) to evaluate top credit union priorities, Delay Section 1071 Rulemaking, Electronic Disclosure Relief and Credit Card Accountability Responsibility and Disclosure Act of 2009 Act (CARD Act) Improvements, Temporarily Halt the Qualified Mortgage (QM) Rulemaking, Revise Home Mortgage Disclosure Act (HMDA) Rule and Reporting, Facilitate the London Interbank Offered Rate (LIBOR) Transition, Unfair, Deceptive, or Abusive Acts and Practices (UDAAP) Guidance and Rulemaking; urge NCUA provide relief to credit unions as they serve their members during the pandemic: Expanding Virtual Meetings, Managing Unexpected Share Growth, Additional Investment Opportunities, Capitalizing Interest on Loan Modifications, Adopting Broader Capital Reform, Finalizing an Efficient and Measured Budget; supports FinCEN defining an overall effective and reasonably designed AML program, including the explicit requirement for a risk-assessment; support automatic loan forgiveness for PPP loans under $150,000 and support any legislative efforts; support legislative efforts to amend the CARES Act to exclude Economic Injury Disaster Loans (EIDL) advance amounts from the calculation of loan forgiveness under the PPP; support initial 3508EZ form and the newly created 3508S form for loans under $50,000; support H.R. 8361, the EIDL Forgiveness Act; recommend a comment period of 90 days for all novel charter applications including the recent filings by Figure Bank for a national charter and Anchorage for a trust charter; TRACED Act; urged the Commission (FCC) not to impose additional restrictions on the existing exemption for informational calls placed to residential telephone numbers (Informational Calls Exemption); urges FinCEN to retain the current Recordkeeping and Travel Rule thresholds; supports the definition of money as proposed, which will resolve ambiguities surrounding applicability to convertible virtual currencies (CVCs); Thresholds for the Requirement to Collect, Retain, and Transmit Information Under the Recordkeeping and Travel Rules (Docket No.: FINCEN-2020-0002; RIN No.: 1506-AB41); Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support increase in size standards for North American Industry Classification System (NAICS) sectors related to finance and insurance, specifically NAICS code 522130 for credit unions; inclusion of S.4117, the Paycheck Protection Small Business Forgiveness Act; support the extensions of the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) and Troubled Debt Restructuring (TDR) provisions from the CARES Act; support focused clarification of regulatory expectations re: ECOA and Reg B; support HUDs codifying court rulings for disparate impact; support extension of CARES Act provisions: Section 1102: Paycheck Protection Program, Section 4012: Community Bank Leverage Ratio, Section 4014: Current Expected Credit Loss (CECL), Section 4008: Deposit Insurance, Section 4013: Troubled Debt Restructuring (TDR), Section 4016: NCUAs Central Liquidity Facility (CLF), Section 1110: Economic Injury Disaster Loan (EIDL) Program; Conference Report for H.R. 6395, the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021; express concern re: The Senates version of the FY 2021 NDAA, S.4049; supports efforts to provide additional emergency funding for CDFIs; outlines several recommendations to improve the efficiency of NCUA budget; bipartisan beneficial ownership and BSA/AML reform legislation - the Corporate Transparency Act and the COUNTER Act; Notice of Ex Parte Presentations, Rules & Regulations Implementing the Tel. Consumer Prot. Act of 1991, CG Docket No. 02-278; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support $25 billion in rental assistance to the Treasury Department to allocate to state and local governments, as well as extends the eviction moratorium; support NCUA modernizing the agencys derivatives rule, changing from a prescriptive approach to a more flexible, principles-based approach; support appreciates the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance ; H.R. 133, the Consolidated Appropriations Act of 2021

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; the CARES Act; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements- oppose fee structure increases; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements; GSEs should provide relief for CUs impacted by forbearances; raise 15-year maturity limit on certain CU loans; Establish an emergency flexible QM standard; Expand definition of Community FI in FHLB Act; expanding membership in FHLBs to include conduits should be explicitly prohibited; Limit liability for Essential Businesses; Assist associations in relief efforts related to COVID-19; do not eliminate courtesy pay; no blanket forbearance in COVID-19 relief; Increase PPP funding; Community Reinvestment Act; delay property tax assessments; FCC should issue an interim declaratory ruling or otherwise act on the Petition on an expedited basis related to autodialing; SBA to issue PPP guidance; H.R. 6550, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; minimize paper payments of Economic Impact payments; Treasury should ensure that all credit unions will be able to receive a payroll tax credit for providing paid sick leave related to COVID-19; support Chairman Hoods request to make changes to the CLF and PCA flexibility during COVID response; third-party vendor examination authority is unnecessary; examiner flexibility with PPP lending; inaccurate call labeling is harmful - provide effective redress; provide equitable access to small lenders for PPP loans and provide transparency related to pacing of applications; improvements to HEROES Act; Support for S. 3833, the Paycheck Protection Program Extension Act; NAFCU urges the NCUA Board to take up Overdraft Policy and approve; Automatic forgiveness of PPP loans under $150k; supportive of efforts to expand financial inclusion, but we are concerned FedAccounts could cause disruptions; oppose adding provision to NDAA that would give banks parity with CUs on military installations; strengthen and improve BSA/AML system while not overburdening CUs support adding Anti-Money Laundering Act of 2020 to NDAA; oppose H.R. 5332, the Protecting Your Credit Score Act; moving the U.S. currency to a federally-backed digital system will have unintended consequences that could affect the privacy of millions of Americans and erode the competitive viability of the U.S. banking system.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; the CARES Act; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements- oppose fee structure increases; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements; GSEs should provide relief for CUs impacted by forbearances; raise 15-year maturity limit on certain CU loans; Establish an emergency flexible QM standard; Expand definition of Community FI in FHLB Act; expanding membership in FHLBs to include conduits should be explicitly prohibited; Limit liability for Essential Businesses; Assist associations in relief efforts related to COVID-19; do not eliminate courtesy pay; no blanket forbearance in COVID-19 relief; Increase PPP funding; Community Reinvestment Act; delay property tax assessments; FCC should issue an interim declaratory ruling or otherwise act on the Petition on an expedited basis related to autodialing; SBA to issue PPP guidance; H.R. 6550, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; minimize paper payments of Economic Impact payments; Treasury should ensure that all credit unions will be able to receive a payroll tax credit for providing paid sick leave related to COVID-19; support Chairman Hoods request to make changes to the CLF and PCA flexibility during COVID response; third-party vendor examination authority is unnecessary; examiner flexibility with PPP lending; inaccurate call labeling is harmful - provide effective redress; provide equitable access to small lenders for PPP loans and provide transparency related to pacing of applications; improvements to HEROES Act; Support for S. 3833, the Paycheck Protection Program Extension Act; NAFCU urges the NCUA Board to take up Overdraft Policy and approve; Automatic forgiveness of PPP loans under $150k; supportive of efforts to expand financial inclusion, but we are concerned FedAccounts could cause disruptions; oppose adding provision to NDAA that would give banks parity with CUs on military installations; strengthen and improve BSA/AML system while not overburdening CUs support adding Anti-Money Laundering Act of 2020 to NDAA; oppose H.R. 5332, the Protecting Your Credit Score Act; moving the U.S. currency to a federally-backed digital system will have unintended consequences that could affect the privacy of millions of Americans and erode the competitive viability of the U.S. banking system.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; the CARES Act; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements- oppose fee structure increases; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements; GSEs should provide relief for CUs impacted by forbearances; raise 15-year maturity limit on certain CU loans; Establish an emergency flexible QM standard; Expand definition of Community FI in FHLB Act; expanding membership in FHLBs to include conduits should be explicitly prohibited; Limit liability for Essential Businesses; Assist associations in relief efforts related to COVID-19; do not eliminate courtesy pay; no blanket forbearance in COVID-19 relief; Increase PPP funding; Community Reinvestment Act; delay property tax assessments; FCC should issue an interim declaratory ruling or otherwise act on the Petition on an expedited basis related to autodialing; SBA to issue PPP guidance; H.R. 6550, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; minimize paper payments of Economic Impact payments; Treasury should ensure that all credit unions will be able to receive a payroll tax credit for providing paid sick leave related to COVID-19; support Chairman Hoods request to make changes to the CLF and PCA flexibility during COVID response; third-party vendor examination authority is unnecessary; examiner flexibility with PPP lending; inaccurate call labeling is harmful - provide effective redress; provide equitable access to small lenders for PPP loans and provide transparency related to pacing of applications; improvements to HEROES Act; Support for S. 3833, the Paycheck Protection Program Extension Act; NAFCU urges the NCUA Board to take up Overdraft Policy and approve; Automatic forgiveness of PPP loans under $150k; supportive of efforts to expand financial inclusion, but we are concerned FedAccounts could cause disruptions; oppose adding provision to NDAA that would give banks parity with CUs on military installations; strengthen and improve BSA/AML system while not overburdening CUs support adding Anti-Money Laundering Act of 2020 to NDAA; oppose H.R. 5332, the Protecting Your Credit Score Act; moving the U.S. currency to a federally-backed digital system will have unintended consequences that could affect the privacy of millions of Americans and erode the competitive viability of the U.S. banking system.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; the CARES Act; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements- oppose fee structure increases; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements; GSEs should provide relief for CUs impacted by forbearances; raise 15-year maturity limit on certain CU loans; Establish an emergency flexible QM standard; Expand definition of Community FI in FHLB Act; expanding membership in FHLBs to include conduits should be explicitly prohibited; Limit liability for Essential Businesses; Assist associations in relief efforts related to COVID-19; do not eliminate courtesy pay; no blanket forbearance in COVID-19 relief; Increase PPP funding; Community Reinvestment Act; delay property tax assessments; FCC should issue an interim declaratory ruling or otherwise act on the Petition on an expedited basis related to autodialing; SBA to issue PPP guidance; H.R. 6550, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; minimize paper payments of Economic Impact payments; Treasury should ensure that all credit unions will be able to receive a payroll tax credit for providing paid sick leave related to COVID-19; support Chairman Hoods request to make changes to the CLF and PCA flexibility during COVID response; third-party vendor examination authority is unnecessary; examiner flexibility with PPP lending; inaccurate call labeling is harmful - provide effective redress; provide equitable access to small lenders for PPP loans and provide transparency related to pacing of applications; improvements to HEROES Act; Support for S. 3833, the Paycheck Protection Program Extension Act; NAFCU urges the NCUA Board to take up Overdraft Policy and approve; Automatic forgiveness of PPP loans under $150k; supportive of efforts to expand financial inclusion, but we are concerned FedAccounts could cause disruptions; oppose adding provision to NDAA that would give banks parity with CUs on military installations; strengthen and improve BSA/AML system while not overburdening CUs support adding Anti-Money Laundering Act of 2020 to NDAA; oppose H.R. 5332, the Protecting Your Credit Score Act; moving the U.S. currency to a federally-backed digital system will have unintended consequences that could affect the privacy of millions of Americans and erode the competitive viability of the U.S. banking system.

Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements.

Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; the CARES Act; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements- oppose fee structure increases; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements; GSEs should provide relief for CUs impacted by forbearances; raise 15-year maturity limit on certain CU loans; Establish an emergency flexible QM standard; Expand definition of Community FI in FHLB Act; expanding membership in FHLBs to include conduits should be explicitly prohibited; Limit liability for Essential Businesses; Assist associations in relief efforts related to COVID-19; do not eliminate courtesy pay; no blanket forbearance in COVID-19 relief; Increase PPP funding; Community Reinvestment Act; delay property tax assessments; FCC should issue an interim declaratory ruling or otherwise act on the Petition on an expedited basis related to autodialing; SBA to issue PPP guidance; H.R. 6550, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; minimize paper payments of Economic Impact payments; Treasury should ensure that all credit unions will be able to receive a payroll tax credit for providing paid sick leave related to COVID-19; support Chairman Hoods request to make changes to the CLF and PCA flexibility during COVID response; third-party vendor examination authority is unnecessary; examiner flexibility with PPP lending; inaccurate call labeling is harmful - provide effective redress; provide equitable access to small lenders for PPP loans and provide transparency related to pacing of applications; improvements to HEROES Act; Support for S. 3833, the Paycheck Protection Program Extension Act; NAFCU urges the NCUA Board to take up Overdraft Policy and approve; Automatic forgiveness of PPP loans under $150k; supportive of efforts to expand financial inclusion, but we are concerned FedAccounts could cause disruptions; oppose adding provision to NDAA that would give banks parity with CUs on military installations; strengthen and improve BSA/AML system while not overburdening CUs support adding Anti-Money Laundering Act of 2020 to NDAA; oppose H.R. 5332, the Protecting Your Credit Score Act; moving the U.S. currency to a federally-backed digital system will have unintended consequences that could affect the privacy of millions of Americans and erode the competitive viability of the U.S. banking system.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; the CARES Act; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements- oppose fee structure increases; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements; GSEs should provide relief for CUs impacted by forbearances; raise 15-year maturity limit on certain CU loans; Establish an emergency flexible QM standard; Expand definition of Community FI in FHLB Act; expanding membership in FHLBs to include conduits should be explicitly prohibited; Limit liability for Essential Businesses; Assist associations in relief efforts related to COVID-19; do not eliminate courtesy pay; no blanket forbearance in COVID-19 relief; Increase PPP funding; Community Reinvestment Act; delay property tax assessments; FCC should issue an interim declaratory ruling or otherwise act on the Petition on an expedited basis related to autodialing; SBA to issue PPP guidance; H.R. 6550, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; minimize paper payments of Economic Impact payments; Treasury should ensure that all credit unions will be able to receive a payroll tax credit for providing paid sick leave related to COVID-19; support Chairman Hoods request to make changes to the CLF and PCA flexibility during COVID response; third-party vendor examination authority is unnecessary; examiner flexibility with PPP lending; inaccurate call labeling is harmful - provide effective redress; provide equitable access to small lenders for PPP loans and provide transparency related to pacing of applications; improvements to HEROES Act; Support for S. 3833, the Paycheck Protection Program Extension Act; NAFCU urges the NCUA Board to take up Overdraft Policy and approve; Automatic forgiveness of PPP loans under $150k; supportive of efforts to expand financial inclusion, but we are concerned FedAccounts could cause disruptions; oppose adding provision to NDAA that would give banks parity with CUs on military installations; strengthen and improve BSA/AML system while not overburdening CUs support adding Anti-Money Laundering Act of 2020 to NDAA; oppose H.R. 5332, the Protecting Your Credit Score Act; moving the U.S. currency to a federally-backed digital system will have unintended consequences that could affect the privacy of millions of Americans and erode the competitive viability of the U.S. banking system.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; the CARES Act; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements- oppose fee structure increases; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements; GSEs should provide relief for CUs impacted by forbearances; raise 15-year maturity limit on certain CU loans; Establish an emergency flexible QM standard; Expand definition of Community FI in FHLB Act; expanding membership in FHLBs to include conduits should be explicitly prohibited; Limit liability for Essential Businesses; Assist associations in relief efforts related to COVID-19; do not eliminate courtesy pay; no blanket forbearance in COVID-19 relief; Increase PPP funding; Community Reinvestment Act; delay property tax assessments; FCC should issue an interim declaratory ruling or otherwise act on the Petition on an expedited basis related to autodialing; SBA to issue PPP guidance; H.R. 6550, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; minimize paper payments of Economic Impact payments; Treasury should ensure that all credit unions will be able to receive a payroll tax credit for providing paid sick leave related to COVID-19; support Chairman Hoods request to make changes to the CLF and PCA flexibility during COVID response; third-party vendor examination authority is unnecessary; examiner flexibility with PPP lending; inaccurate call labeling is harmful - provide effective redress; provide equitable access to small lenders for PPP loans and provide transparency related to pacing of applications; improvements to HEROES Act; Support for S. 3833, the Paycheck Protection Program Extension Act; NAFCU urges the NCUA Board to take up Overdraft Policy and approve; Automatic forgiveness of PPP loans under $150k; supportive of efforts to expand financial inclusion, but we are concerned FedAccounts could cause disruptions; oppose adding provision to NDAA that would give banks parity with CUs on military installations; strengthen and improve BSA/AML system while not overburdening CUs support adding Anti-Money Laundering Act of 2020 to NDAA; oppose H.R. 5332, the Protecting Your Credit Score Act; moving the U.S. currency to a federally-backed digital system will have unintended consequences that could affect the privacy of millions of Americans and erode the competitive viability of the U.S. banking system.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; the CARES Act; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements- oppose fee structure increases; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements; GSEs should provide relief for CUs impacted by forbearances; raise 15-year maturity limit on certain CU loans; Establish an emergency flexible QM standard; Expand definition of Community FI in FHLB Act; expanding membership in FHLBs to include conduits should be explicitly prohibited; Limit liability for Essential Businesses; Assist associations in relief efforts related to COVID-19; do not eliminate courtesy pay; no blanket forbearance in COVID-19 relief; Increase PPP funding; Community Reinvestment Act; delay property tax assessments; FCC should issue an interim declaratory ruling or otherwise act on the Petition on an expedited basis related to autodialing; SBA to issue PPP guidance; H.R. 6550, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; minimize paper payments of Economic Impact payments; Treasury should ensure that all credit unions will be able to receive a payroll tax credit for providing paid sick leave related to COVID-19; support Chairman Hoods request to make changes to the CLF and PCA flexibility during COVID response; third-party vendor examination authority is unnecessary; examiner flexibility with PPP lending; inaccurate call labeling is harmful - provide effective redress; provide equitable access to small lenders for PPP loans and provide transparency related to pacing of applications; improvements to HEROES Act; Support for S. 3833, the Paycheck Protection Program Extension Act; NAFCU urges the NCUA Board to take up Overdraft Policy and approve; Automatic forgiveness of PPP loans under $150k; supportive of efforts to expand financial inclusion, but we are concerned FedAccounts could cause disruptions; oppose adding provision to NDAA that would give banks parity with CUs on military installations; strengthen and improve BSA/AML system while not overburdening CUs support adding Anti-Money Laundering Act of 2020 to NDAA; oppose H.R. 5332, the Protecting Your Credit Score Act; moving the U.S. currency to a federally-backed digital system will have unintended consequences that could affect the privacy of millions of Americans and erode the competitive viability of the U.S. banking system.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; the CARES Act; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements- oppose fee structure increases; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements; GSEs should provide relief for CUs impacted by forbearances; raise 15-year maturity limit on certain CU loans; Establish an emergency flexible QM standard; Expand definition of Community FI in FHLB Act; expanding membership in FHLBs to include conduits should be explicitly prohibited; Limit liability for Essential Businesses; Assist associations in relief efforts related to COVID-19; do not eliminate courtesy pay; no blanket forbearance in COVID-19 relief; Increase PPP funding; Community Reinvestment Act; delay property tax assessments; FCC should issue an interim declaratory ruling or otherwise act on the Petition on an expedited basis related to autodialing; SBA to issue PPP guidance; H.R. 6550, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; minimize paper payments of Economic Impact payments; Treasury should ensure that all credit unions will be able to receive a payroll tax credit for providing paid sick leave related to COVID-19; support Chairman Hoods request to make changes to the CLF and PCA flexibility during COVID response; third-party vendor examination authority is unnecessary; examiner flexibility with PPP lending; inaccurate call labeling is harmful - provide effective redress; provide equitable access to small lenders for PPP loans and provide transparency related to pacing of applications; improvements to HEROES Act; Support for S. 3833, the Paycheck Protection Program Extension Act; NAFCU urges the NCUA Board to take up Overdraft Policy and approve; Automatic forgiveness of PPP loans under $150k; supportive of efforts to expand financial inclusion, but we are concerned FedAccounts could cause disruptions; oppose adding provision to NDAA that would give banks parity with CUs on military installations; strengthen and improve BSA/AML system while not overburdening CUs support adding Anti-Money Laundering Act of 2020 to NDAA; oppose H.R. 5332, the Protecting Your Credit Score Act; moving the U.S. currency to a federally-backed digital system will have unintended consequences that could affect the privacy of millions of Americans and erode the competitive viability of the U.S. banking system.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; the CARES Act; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements- oppose fee structure increases; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements; GSEs should provide relief for CUs impacted by forbearances; raise 15-year maturity limit on certain CU loans; Establish an emergency flexible QM standard; Expand definition of Community FI in FHLB Act; expanding membership in FHLBs to include conduits should be explicitly prohibited; Limit liability for Essential Businesses; Assist associations in relief efforts related to COVID-19; do not eliminate courtesy pay; no blanket forbearance in COVID-19 relief; Increase PPP funding; Community Reinvestment Act; delay property tax assessments; FCC should issue an interim declaratory ruling or otherwise act on the Petition on an expedited basis related to autodialing; SBA to issue PPP guidance; H.R. 6550, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; minimize paper payments of Economic Impact payments; Treasury should ensure that all credit unions will be able to receive a payroll tax credit for providing paid sick leave related to COVID-19; support Chairman Hoods request to make changes to the CLF and PCA flexibility during COVID response; third-party vendor examination authority is unnecessary; examiner flexibility with PPP lending; inaccurate call labeling is harmful - provide effective redress; provide equitable access to small lenders for PPP loans and provide transparency related to pacing of applications; improvements to HEROES Act; Support for S. 3833, the Paycheck Protection Program Extension Act; NAFCU urges the NCUA Board to take up Overdraft Policy and approve; Automatic forgiveness of PPP loans under $150k; supportive of efforts to expand financial inclusion, but we are concerned FedAccounts could cause disruptions; oppose adding provision to NDAA that would give banks parity with CUs on military installations; strengthen and improve BSA/AML system while not overburdening CUs support adding Anti-Money Laundering Act of 2020 to NDAA; oppose H.R. 5332, the Protecting Your Credit Score Act; moving the U.S. currency to a federally-backed digital system will have unintended consequences that could affect the privacy of millions of Americans and erode the competitive viability of the U.S. banking system.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements.

Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act

Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act

Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act

Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; Overhead Transfer Rate (OTR) methodology and operating fee schedule; support of the FCC's efforts to establish and implement exemptions to the TCPAs consent requirement for important information about fraudulent activity, data breaches and available protections, and money transfers; supportive of the FCCs proposal to not limit the number of calls made under the exemption; Comment on Annual Certification and Data Collection Report Form (ACR) and the Certification Transaction Level Report (CTLR), concerned about the reporting burden and cybersecurity risks associated with the proposed ACR and CTRL; support the certainty and regulatory flexibility afforded by many of the new and updated Interagency Questions and Answers regarding flood insurance; express concern the proposed Community Development Financial Institutions Program application creates many such barriers, which ultimately will make it more difficult and unlikely that credit unions will obtain and maintain CDFI-designation; urge the Federal Housing Finance Agency (FHFA) to evaluate top credit union regulatory priorities, Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the National Credit Union Administration (NCUA) to evaluate the priority issues and enact the requested policy modifications re: Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the U.S. Department of the Treasury (Treasury) along with the Financial Crimes Enforcement Network (FinCEN) and the Internal Revenue Service (IRS) to evaluate the top credit union priorities; express concern with Section 2885 of S.4049, which would expand access to nominal leases on military installations for banks; support for Division F, the Corporate Transparency Act of 2019 and Division G, the COUNTER Act of 2019, of H.R.6395, which would make critical improvements to our Bank Secrecy Act (BSA)/anti-money laundering (AML)/beneficial ownership regime; support of a simplified loan forgiveness process for PPP loans under a $150,000 threshold, such as proposed in H.R.7777/S.4117, the Paycheck Protection Small Business Forgiveness Act; support a second round of PPP loans to the hardest hit small businesses; extend the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) that were enacted in section 4016 of the CARES Act and to extend the provisions from section 4013 of the CARES Act dealing with Troubled Debt Restructuring (TDR); support H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020; support excluding EIDL advances from the PPP forgiveness calculation, as proposed by bipartisan legislation in the House, HR.8361, the EIDL Forgiveness Act; supports legislation, H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020, which would provide temporary relief from the credit union member business lending (MBL) cap; support increase funding for the CDFI and CDRLF programs. Providing $1 billion in emergency funding for the CDFI Fund would allow more credit unions to access monies for specific programs; support the Health and Economic Recovery Omnibus Emergency Solutions Act (HEROES Act); support the inclusion of S.4159, the E-SIGN Modernization Act of 2020, in the relief package; credit unions, as not-for-profit cooperative institutions, should not be subject to the CECL standard; support a reduction in the level at which credit unions are considered well capitalized from a net-worth ratio of seven percent to six percent and adequately capitalized from six percent to five percent during the pandemic; reject any idea, even if well-meaning, that could place new hardships on credit unions; urges the Bureau of Consumer Financial Protection (Bureau or CFPB) to evaluate top credit union priorities, Delay Section 1071 Rulemaking, Electronic Disclosure Relief and Credit Card Accountability Responsibility and Disclosure Act of 2009 Act (CARD Act) Improvements, Temporarily Halt the Qualified Mortgage (QM) Rulemaking, Revise Home Mortgage Disclosure Act (HMDA) Rule and Reporting, Facilitate the London Interbank Offered Rate (LIBOR) Transition, Unfair, Deceptive, or Abusive Acts and Practices (UDAAP) Guidance and Rulemaking; urge NCUA provide relief to credit unions as they serve their members during the pandemic: Expanding Virtual Meetings, Managing Unexpected Share Growth, Additional Investment Opportunities, Capitalizing Interest on Loan Modifications, Adopting Broader Capital Reform, Finalizing an Efficient and Measured Budget; supports FinCEN defining an overall effective and reasonably designed AML program, including the explicit requirement for a risk-assessment; support automatic loan forgiveness for PPP loans under $150,000 and support any legislative efforts; support legislative efforts to amend the CARES Act to exclude Economic Injury Disaster Loans (EIDL) advance amounts from the calculation of loan forgiveness under the PPP; support initial 3508EZ form and the newly created 3508S form for loans under $50,000; support H.R. 8361, the EIDL Forgiveness Act; recommend a comment period of 90 days for all novel charter applications including the recent filings by Figure Bank for a national charter and Anchorage for a trust charter; TRACED Act; urged the Commission (FCC) not to impose additional restrictions on the existing exemption for informational calls placed to residential telephone numbers (Informational Calls Exemption); urges FinCEN to retain the current Recordkeeping and Travel Rule thresholds; supports the definition of money as proposed, which will resolve ambiguities surrounding applicability to convertible virtual currencies (CVCs); Thresholds for the Requirement to Collect, Retain, and Transmit Information Under the Recordkeeping and Travel Rules (Docket No.: FINCEN-2020-0002; RIN No.: 1506-AB41); Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support increase in size standards for North American Industry Classification System (NAICS) sectors related to finance and insurance, specifically NAICS code 522130 for credit unions; inclusion of S.4117, the Paycheck Protection Small Business Forgiveness Act; support the extensions of the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) and Troubled Debt Restructuring (TDR) provisions from the CARES Act; support focused clarification of regulatory expectations re: ECOA and Reg B; support HUDs codifying court rulings for disparate impact; support extension of CARES Act provisions: Section 1102: Paycheck Protection Program, Section 4012: Community Bank Leverage Ratio, Section 4014: Current Expected Credit Loss (CECL), Section 4008: Deposit Insurance, Section 4013: Troubled Debt Restructuring (TDR), Section 4016: NCUAs Central Liquidity Facility (CLF), Section 1110: Economic Injury Disaster Loan (EIDL) Program; Conference Report for H.R. 6395, the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021; express concern re: The Senates version of the FY 2021 NDAA, S.4049; supports efforts to provide additional emergency funding for CDFIs; outlines several recommendations to improve the efficiency of NCUA budget; bipartisan beneficial ownership and BSA/AML reform legislation - the Corporate Transparency Act and the COUNTER Act; Notice of Ex Parte Presentations, Rules & Regulations Implementing the Tel. Consumer Prot. Act of 1991, CG Docket No. 02-278; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support $25 billion in rental assistance to the Treasury Department to allocate to state and local governments, as well as extends the eviction moratorium; support NCUA modernizing the agencys derivatives rule, changing from a prescriptive approach to a more flexible, principles-based approach; support appreciates the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance ; H.R. 133, the Consolidated Appropriations Act of 2021

Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act

Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; Overhead Transfer Rate (OTR) methodology and operating fee schedule; support of the FCC's efforts to establish and implement exemptions to the TCPAs consent requirement for important information about fraudulent activity, data breaches and available protections, and money transfers; supportive of the FCCs proposal to not limit the number of calls made under the exemption; Comment on Annual Certification and Data Collection Report Form (ACR) and the Certification Transaction Level Report (CTLR), concerned about the reporting burden and cybersecurity risks associated with the proposed ACR and CTRL; support the certainty and regulatory flexibility afforded by many of the new and updated Interagency Questions and Answers regarding flood insurance; express concern the proposed Community Development Financial Institutions Program application creates many such barriers, which ultimately will make it more difficult and unlikely that credit unions will obtain and maintain CDFI-designation; urge the Federal Housing Finance Agency (FHFA) to evaluate top credit union regulatory priorities, Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the National Credit Union Administration (NCUA) to evaluate the priority issues and enact the requested policy modifications re: Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the U.S. Department of the Treasury (Treasury) along with the Financial Crimes Enforcement Network (FinCEN) and the Internal Revenue Service (IRS) to evaluate the top credit union priorities; express concern with Section 2885 of S.4049, which would expand access to nominal leases on military installations for banks; support for Division F, the Corporate Transparency Act of 2019 and Division G, the COUNTER Act of 2019, of H.R.6395, which would make critical improvements to our Bank Secrecy Act (BSA)/anti-money laundering (AML)/beneficial ownership regime; support of a simplified loan forgiveness process for PPP loans under a $150,000 threshold, such as proposed in H.R.7777/S.4117, the Paycheck Protection Small Business Forgiveness Act; support a second round of PPP loans to the hardest hit small businesses; extend the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) that were enacted in section 4016 of the CARES Act and to extend the provisions from section 4013 of the CARES Act dealing with Troubled Debt Restructuring (TDR); support H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020; support excluding EIDL advances from the PPP forgiveness calculation, as proposed by bipartisan legislation in the House, HR.8361, the EIDL Forgiveness Act; supports legislation, H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020, which would provide temporary relief from the credit union member business lending (MBL) cap; support increase funding for the CDFI and CDRLF programs. Providing $1 billion in emergency funding for the CDFI Fund would allow more credit unions to access monies for specific programs; support the Health and Economic Recovery Omnibus Emergency Solutions Act (HEROES Act); support the inclusion of S.4159, the E-SIGN Modernization Act of 2020, in the relief package; credit unions, as not-for-profit cooperative institutions, should not be subject to the CECL standard; support a reduction in the level at which credit unions are considered well capitalized from a net-worth ratio of seven percent to six percent and adequately capitalized from six percent to five percent during the pandemic; reject any idea, even if well-meaning, that could place new hardships on credit unions; urges the Bureau of Consumer Financial Protection (Bureau or CFPB) to evaluate top credit union priorities, Delay Section 1071 Rulemaking, Electronic Disclosure Relief and Credit Card Accountability Responsibility and Disclosure Act of 2009 Act (CARD Act) Improvements, Temporarily Halt the Qualified Mortgage (QM) Rulemaking, Revise Home Mortgage Disclosure Act (HMDA) Rule and Reporting, Facilitate the London Interbank Offered Rate (LIBOR) Transition, Unfair, Deceptive, or Abusive Acts and Practices (UDAAP) Guidance and Rulemaking; urge NCUA provide relief to credit unions as they serve their members during the pandemic: Expanding Virtual Meetings, Managing Unexpected Share Growth, Additional Investment Opportunities, Capitalizing Interest on Loan Modifications, Adopting Broader Capital Reform, Finalizing an Efficient and Measured Budget; supports FinCEN defining an overall effective and reasonably designed AML program, including the explicit requirement for a risk-assessment; support automatic loan forgiveness for PPP loans under $150,000 and support any legislative efforts; support legislative efforts to amend the CARES Act to exclude Economic Injury Disaster Loans (EIDL) advance amounts from the calculation of loan forgiveness under the PPP; support initial 3508EZ form and the newly created 3508S form for loans under $50,000; support H.R. 8361, the EIDL Forgiveness Act; recommend a comment period of 90 days for all novel charter applications including the recent filings by Figure Bank for a national charter and Anchorage for a trust charter; TRACED Act; urged the Commission (FCC) not to impose additional restrictions on the existing exemption for informational calls placed to residential telephone numbers (Informational Calls Exemption); urges FinCEN to retain the current Recordkeeping and Travel Rule thresholds; supports the definition of money as proposed, which will resolve ambiguities surrounding applicability to convertible virtual currencies (CVCs); Thresholds for the Requirement to Collect, Retain, and Transmit Information Under the Recordkeeping and Travel Rules (Docket No.: FINCEN-2020-0002; RIN No.: 1506-AB41); Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support increase in size standards for North American Industry Classification System (NAICS) sectors related to finance and insurance, specifically NAICS code 522130 for credit unions; inclusion of S.4117, the Paycheck Protection Small Business Forgiveness Act; support the extensions of the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) and Troubled Debt Restructuring (TDR) provisions from the CARES Act; support focused clarification of regulatory expectations re: ECOA and Reg B; support HUDs codifying court rulings for disparate impact; support extension of CARES Act provisions: Section 1102: Paycheck Protection Program, Section 4012: Community Bank Leverage Ratio, Section 4014: Current Expected Credit Loss (CECL), Section 4008: Deposit Insurance, Section 4013: Troubled Debt Restructuring (TDR), Section 4016: NCUAs Central Liquidity Facility (CLF), Section 1110: Economic Injury Disaster Loan (EIDL) Program; Conference Report for H.R. 6395, the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021; express concern re: The Senates version of the FY 2021 NDAA, S.4049; supports efforts to provide additional emergency funding for CDFIs; outlines several recommendations to improve the efficiency of NCUA budget; bipartisan beneficial ownership and BSA/AML reform legislation - the Corporate Transparency Act and the COUNTER Act; Notice of Ex Parte Presentations, Rules & Regulations Implementing the Tel. Consumer Prot. Act of 1991, CG Docket No. 02-278; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support $25 billion in rental assistance to the Treasury Department to allocate to state and local governments, as well as extends the eviction moratorium; support NCUA modernizing the agencys derivatives rule, changing from a prescriptive approach to a more flexible, principles-based approach; support appreciates the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance ; H.R. 133, the Consolidated Appropriations Act of 2021

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; the CARES Act; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements- oppose fee structure increases; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements; GSEs should provide relief for CUs impacted by forbearances; raise 15-year maturity limit on certain CU loans; Establish an emergency flexible QM standard; Expand definition of Community FI in FHLB Act; expanding membership in FHLBs to include conduits should be explicitly prohibited; Limit liability for Essential Businesses; Assist associations in relief efforts related to COVID-19; do not eliminate courtesy pay; no blanket forbearance in COVID-19 relief; Increase PPP funding; Community Reinvestment Act; delay property tax assessments; FCC should issue an interim declaratory ruling or otherwise act on the Petition on an expedited basis related to autodialing; SBA to issue PPP guidance; H.R. 6550, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; minimize paper payments of Economic Impact payments; Treasury should ensure that all credit unions will be able to receive a payroll tax credit for providing paid sick leave related to COVID-19; support Chairman Hoods request to make changes to the CLF and PCA flexibility during COVID response; third-party vendor examination authority is unnecessary; examiner flexibility with PPP lending; inaccurate call labeling is harmful - provide effective redress; provide equitable access to small lenders for PPP loans and provide transparency related to pacing of applications; improvements to HEROES Act; Support for S. 3833, the Paycheck Protection Program Extension Act; NAFCU urges the NCUA Board to take up Overdraft Policy and approve; Automatic forgiveness of PPP loans under $150k; supportive of efforts to expand financial inclusion, but we are concerned FedAccounts could cause disruptions; oppose adding provision to NDAA that would give banks parity with CUs on military installations; strengthen and improve BSA/AML system while not overburdening CUs support adding Anti-Money Laundering Act of 2020 to NDAA; oppose H.R. 5332, the Protecting Your Credit Score Act; moving the U.S. currency to a federally-backed digital system will have unintended consequences that could affect the privacy of millions of Americans and erode the competitive viability of the U.S. banking system.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; the CARES Act; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements- oppose fee structure increases; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements; GSEs should provide relief for CUs impacted by forbearances; raise 15-year maturity limit on certain CU loans; Establish an emergency flexible QM standard; Expand definition of Community FI in FHLB Act; expanding membership in FHLBs to include conduits should be explicitly prohibited; Limit liability for Essential Businesses; Assist associations in relief efforts related to COVID-19; do not eliminate courtesy pay; no blanket forbearance in COVID-19 relief; Increase PPP funding; Community Reinvestment Act; delay property tax assessments; FCC should issue an interim declaratory ruling or otherwise act on the Petition on an expedited basis related to autodialing; SBA to issue PPP guidance; H.R. 6550, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; minimize paper payments of Economic Impact payments; Treasury should ensure that all credit unions will be able to receive a payroll tax credit for providing paid sick leave related to COVID-19; support Chairman Hoods request to make changes to the CLF and PCA flexibility during COVID response; third-party vendor examination authority is unnecessary; examiner flexibility with PPP lending; inaccurate call labeling is harmful - provide effective redress; provide equitable access to small lenders for PPP loans and provide transparency related to pacing of applications; improvements to HEROES Act; Support for S. 3833, the Paycheck Protection Program Extension Act; NAFCU urges the NCUA Board to take up Overdraft Policy and approve; Automatic forgiveness of PPP loans under $150k; supportive of efforts to expand financial inclusion, but we are concerned FedAccounts could cause disruptions; oppose adding provision to NDAA that would give banks parity with CUs on military installations; strengthen and improve BSA/AML system while not overburdening CUs support adding Anti-Money Laundering Act of 2020 to NDAA; oppose H.R. 5332, the Protecting Your Credit Score Act; moving the U.S. currency to a federally-backed digital system will have unintended consequences that could affect the privacy of millions of Americans and erode the competitive viability of the U.S. banking system.

Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; Overhead Transfer Rate (OTR) methodology and operating fee schedule; support of the FCC's efforts to establish and implement exemptions to the TCPAs consent requirement for important information about fraudulent activity, data breaches and available protections, and money transfers; supportive of the FCCs proposal to not limit the number of calls made under the exemption; Comment on Annual Certification and Data Collection Report Form (ACR) and the Certification Transaction Level Report (CTLR), concerned about the reporting burden and cybersecurity risks associated with the proposed ACR and CTRL; support the certainty and regulatory flexibility afforded by many of the new and updated Interagency Questions and Answers regarding flood insurance; express concern the proposed Community Development Financial Institutions Program application creates many such barriers, which ultimately will make it more difficult and unlikely that credit unions will obtain and maintain CDFI-designation; urge the Federal Housing Finance Agency (FHFA) to evaluate top credit union regulatory priorities, Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the National Credit Union Administration (NCUA) to evaluate the priority issues and enact the requested policy modifications re: Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the U.S. Department of the Treasury (Treasury) along with the Financial Crimes Enforcement Network (FinCEN) and the Internal Revenue Service (IRS) to evaluate the top credit union priorities; express concern with Section 2885 of S.4049, which would expand access to nominal leases on military installations for banks; support for Division F, the Corporate Transparency Act of 2019 and Division G, the COUNTER Act of 2019, of H.R.6395, which would make critical improvements to our Bank Secrecy Act (BSA)/anti-money laundering (AML)/beneficial ownership regime; support of a simplified loan forgiveness process for PPP loans under a $150,000 threshold, such as proposed in H.R.7777/S.4117, the Paycheck Protection Small Business Forgiveness Act; support a second round of PPP loans to the hardest hit small businesses; extend the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) that were enacted in section 4016 of the CARES Act and to extend the provisions from section 4013 of the CARES Act dealing with Troubled Debt Restructuring (TDR); support H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020; support excluding EIDL advances from the PPP forgiveness calculation, as proposed by bipartisan legislation in the House, HR.8361, the EIDL Forgiveness Act; supports legislation, H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020, which would provide temporary relief from the credit union member business lending (MBL) cap; support increase funding for the CDFI and CDRLF programs. Providing $1 billion in emergency funding for the CDFI Fund would allow more credit unions to access monies for specific programs; support the Health and Economic Recovery Omnibus Emergency Solutions Act (HEROES Act); support the inclusion of S.4159, the E-SIGN Modernization Act of 2020, in the relief package; credit unions, as not-for-profit cooperative institutions, should not be subject to the CECL standard; support a reduction in the level at which credit unions are considered well capitalized from a net-worth ratio of seven percent to six percent and adequately capitalized from six percent to five percent during the pandemic; reject any idea, even if well-meaning, that could place new hardships on credit unions; urges the Bureau of Consumer Financial Protection (Bureau or CFPB) to evaluate top credit union priorities, Delay Section 1071 Rulemaking, Electronic Disclosure Relief and Credit Card Accountability Responsibility and Disclosure Act of 2009 Act (CARD Act) Improvements, Temporarily Halt the Qualified Mortgage (QM) Rulemaking, Revise Home Mortgage Disclosure Act (HMDA) Rule and Reporting, Facilitate the London Interbank Offered Rate (LIBOR) Transition, Unfair, Deceptive, or Abusive Acts and Practices (UDAAP) Guidance and Rulemaking; urge NCUA provide relief to credit unions as they serve their members during the pandemic: Expanding Virtual Meetings, Managing Unexpected Share Growth, Additional Investment Opportunities, Capitalizing Interest on Loan Modifications, Adopting Broader Capital Reform, Finalizing an Efficient and Measured Budget; supports FinCEN defining an overall effective and reasonably designed AML program, including the explicit requirement for a risk-assessment; support automatic loan forgiveness for PPP loans under $150,000 and support any legislative efforts; support legislative efforts to amend the CARES Act to exclude Economic Injury Disaster Loans (EIDL) advance amounts from the calculation of loan forgiveness under the PPP; support initial 3508EZ form and the newly created 3508S form for loans under $50,000; support H.R. 8361, the EIDL Forgiveness Act; recommend a comment period of 90 days for all novel charter applications including the recent filings by Figure Bank for a national charter and Anchorage for a trust charter; TRACED Act; urged the Commission (FCC) not to impose additional restrictions on the existing exemption for informational calls placed to residential telephone numbers (Informational Calls Exemption); urges FinCEN to retain the current Recordkeeping and Travel Rule thresholds; supports the definition of money as proposed, which will resolve ambiguities surrounding applicability to convertible virtual currencies (CVCs); Thresholds for the Requirement to Collect, Retain, and Transmit Information Under the Recordkeeping and Travel Rules (Docket No.: FINCEN-2020-0002; RIN No.: 1506-AB41); Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support increase in size standards for North American Industry Classification System (NAICS) sectors related to finance and insurance, specifically NAICS code 522130 for credit unions; inclusion of S.4117, the Paycheck Protection Small Business Forgiveness Act; support the extensions of the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) and Troubled Debt Restructuring (TDR) provisions from the CARES Act; support focused clarification of regulatory expectations re: ECOA and Reg B; support HUDs codifying court rulings for disparate impact; support extension of CARES Act provisions: Section 1102: Paycheck Protection Program, Section 4012: Community Bank Leverage Ratio, Section 4014: Current Expected Credit Loss (CECL), Section 4008: Deposit Insurance, Section 4013: Troubled Debt Restructuring (TDR), Section 4016: NCUAs Central Liquidity Facility (CLF), Section 1110: Economic Injury Disaster Loan (EIDL) Program; Conference Report for H.R. 6395, the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021; express concern re: The Senates version of the FY 2021 NDAA, S.4049; supports efforts to provide additional emergency funding for CDFIs; outlines several recommendations to improve the efficiency of NCUA budget; bipartisan beneficial ownership and BSA/AML reform legislation - the Corporate Transparency Act and the COUNTER Act; Notice of Ex Parte Presentations, Rules & Regulations Implementing the Tel. Consumer Prot. Act of 1991, CG Docket No. 02-278; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support $25 billion in rental assistance to the Treasury Department to allocate to state and local governments, as well as extends the eviction moratorium; support NCUA modernizing the agencys derivatives rule, changing from a prescriptive approach to a more flexible, principles-based approach; support appreciates the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance ; H.R. 133, the Consolidated Appropriations Act of 2021

Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; Overhead Transfer Rate (OTR) methodology and operating fee schedule; support of the FCC's efforts to establish and implement exemptions to the TCPAs consent requirement for important information about fraudulent activity, data breaches and available protections, and money transfers; supportive of the FCCs proposal to not limit the number of calls made under the exemption; Comment on Annual Certification and Data Collection Report Form (ACR) and the Certification Transaction Level Report (CTLR), concerned about the reporting burden and cybersecurity risks associated with the proposed ACR and CTRL; support the certainty and regulatory flexibility afforded by many of the new and updated Interagency Questions and Answers regarding flood insurance; express concern the proposed Community Development Financial Institutions Program application creates many such barriers, which ultimately will make it more difficult and unlikely that credit unions will obtain and maintain CDFI-designation; urge the Federal Housing Finance Agency (FHFA) to evaluate top credit union regulatory priorities, Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the National Credit Union Administration (NCUA) to evaluate the priority issues and enact the requested policy modifications re: Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the U.S. Department of the Treasury (Treasury) along with the Financial Crimes Enforcement Network (FinCEN) and the Internal Revenue Service (IRS) to evaluate the top credit union priorities; express concern with Section 2885 of S.4049, which would expand access to nominal leases on military installations for banks; support for Division F, the Corporate Transparency Act of 2019 and Division G, the COUNTER Act of 2019, of H.R.6395, which would make critical improvements to our Bank Secrecy Act (BSA)/anti-money laundering (AML)/beneficial ownership regime; support of a simplified loan forgiveness process for PPP loans under a $150,000 threshold, such as proposed in H.R.7777/S.4117, the Paycheck Protection Small Business Forgiveness Act; support a second round of PPP loans to the hardest hit small businesses; extend the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) that were enacted in section 4016 of the CARES Act and to extend the provisions from section 4013 of the CARES Act dealing with Troubled Debt Restructuring (TDR); support H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020; support excluding EIDL advances from the PPP forgiveness calculation, as proposed by bipartisan legislation in the House, HR.8361, the EIDL Forgiveness Act; supports legislation, H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020, which would provide temporary relief from the credit union member business lending (MBL) cap; support increase funding for the CDFI and CDRLF programs. Providing $1 billion in emergency funding for the CDFI Fund would allow more credit unions to access monies for specific programs; support the Health and Economic Recovery Omnibus Emergency Solutions Act (HEROES Act); support the inclusion of S.4159, the E-SIGN Modernization Act of 2020, in the relief package; credit unions, as not-for-profit cooperative institutions, should not be subject to the CECL standard; support a reduction in the level at which credit unions are considered well capitalized from a net-worth ratio of seven percent to six percent and adequately capitalized from six percent to five percent during the pandemic; reject any idea, even if well-meaning, that could place new hardships on credit unions; urges the Bureau of Consumer Financial Protection (Bureau or CFPB) to evaluate top credit union priorities, Delay Section 1071 Rulemaking, Electronic Disclosure Relief and Credit Card Accountability Responsibility and Disclosure Act of 2009 Act (CARD Act) Improvements, Temporarily Halt the Qualified Mortgage (QM) Rulemaking, Revise Home Mortgage Disclosure Act (HMDA) Rule and Reporting, Facilitate the London Interbank Offered Rate (LIBOR) Transition, Unfair, Deceptive, or Abusive Acts and Practices (UDAAP) Guidance and Rulemaking; urge NCUA provide relief to credit unions as they serve their members during the pandemic: Expanding Virtual Meetings, Managing Unexpected Share Growth, Additional Investment Opportunities, Capitalizing Interest on Loan Modifications, Adopting Broader Capital Reform, Finalizing an Efficient and Measured Budget; supports FinCEN defining an overall effective and reasonably designed AML program, including the explicit requirement for a risk-assessment; support automatic loan forgiveness for PPP loans under $150,000 and support any legislative efforts; support legislative efforts to amend the CARES Act to exclude Economic Injury Disaster Loans (EIDL) advance amounts from the calculation of loan forgiveness under the PPP; support initial 3508EZ form and the newly created 3508S form for loans under $50,000; support H.R. 8361, the EIDL Forgiveness Act; recommend a comment period of 90 days for all novel charter applications including the recent filings by Figure Bank for a national charter and Anchorage for a trust charter; TRACED Act; urged the Commission (FCC) not to impose additional restrictions on the existing exemption for informational calls placed to residential telephone numbers (Informational Calls Exemption); urges FinCEN to retain the current Recordkeeping and Travel Rule thresholds; supports the definition of money as proposed, which will resolve ambiguities surrounding applicability to convertible virtual currencies (CVCs); Thresholds for the Requirement to Collect, Retain, and Transmit Information Under the Recordkeeping and Travel Rules (Docket No.: FINCEN-2020-0002; RIN No.: 1506-AB41); Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support increase in size standards for North American Industry Classification System (NAICS) sectors related to finance and insurance, specifically NAICS code 522130 for credit unions; inclusion of S.4117, the Paycheck Protection Small Business Forgiveness Act; support the extensions of the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) and Troubled Debt Restructuring (TDR) provisions from the CARES Act; support focused clarification of regulatory expectations re: ECOA and Reg B; support HUDs codifying court rulings for disparate impact; support extension of CARES Act provisions: Section 1102: Paycheck Protection Program, Section 4012: Community Bank Leverage Ratio, Section 4014: Current Expected Credit Loss (CECL), Section 4008: Deposit Insurance, Section 4013: Troubled Debt Restructuring (TDR), Section 4016: NCUAs Central Liquidity Facility (CLF), Section 1110: Economic Injury Disaster Loan (EIDL) Program; Conference Report for H.R. 6395, the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021; express concern re: The Senates version of the FY 2021 NDAA, S.4049; supports efforts to provide additional emergency funding for CDFIs; outlines several recommendations to improve the efficiency of NCUA budget; bipartisan beneficial ownership and BSA/AML reform legislation - the Corporate Transparency Act and the COUNTER Act; Notice of Ex Parte Presentations, Rules & Regulations Implementing the Tel. Consumer Prot. Act of 1991, CG Docket No. 02-278; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support $25 billion in rental assistance to the Treasury Department to allocate to state and local governments, as well as extends the eviction moratorium; support NCUA modernizing the agencys derivatives rule, changing from a prescriptive approach to a more flexible, principles-based approach; support appreciates the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance ; H.R. 133, the Consolidated Appropriations Act of 2021

Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act

Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act

Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; Overhead Transfer Rate (OTR) methodology and operating fee schedule; support of the FCC's efforts to establish and implement exemptions to the TCPAs consent requirement for important information about fraudulent activity, data breaches and available protections, and money transfers; supportive of the FCCs proposal to not limit the number of calls made under the exemption; Comment on Annual Certification and Data Collection Report Form (ACR) and the Certification Transaction Level Report (CTLR), concerned about the reporting burden and cybersecurity risks associated with the proposed ACR and CTRL; support the certainty and regulatory flexibility afforded by many of the new and updated Interagency Questions and Answers regarding flood insurance; express concern the proposed Community Development Financial Institutions Program application creates many such barriers, which ultimately will make it more difficult and unlikely that credit unions will obtain and maintain CDFI-designation; urge the Federal Housing Finance Agency (FHFA) to evaluate top credit union regulatory priorities, Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the National Credit Union Administration (NCUA) to evaluate the priority issues and enact the requested policy modifications re: Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the U.S. Department of the Treasury (Treasury) along with the Financial Crimes Enforcement Network (FinCEN) and the Internal Revenue Service (IRS) to evaluate the top credit union priorities; express concern with Section 2885 of S.4049, which would expand access to nominal leases on military installations for banks; support for Division F, the Corporate Transparency Act of 2019 and Division G, the COUNTER Act of 2019, of H.R.6395, which would make critical improvements to our Bank Secrecy Act (BSA)/anti-money laundering (AML)/beneficial ownership regime; support of a simplified loan forgiveness process for PPP loans under a $150,000 threshold, such as proposed in H.R.7777/S.4117, the Paycheck Protection Small Business Forgiveness Act; support a second round of PPP loans to the hardest hit small businesses; extend the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) that were enacted in section 4016 of the CARES Act and to extend the provisions from section 4013 of the CARES Act dealing with Troubled Debt Restructuring (TDR); support H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020; support excluding EIDL advances from the PPP forgiveness calculation, as proposed by bipartisan legislation in the House, HR.8361, the EIDL Forgiveness Act; supports legislation, H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020, which would provide temporary relief from the credit union member business lending (MBL) cap; support increase funding for the CDFI and CDRLF programs. Providing $1 billion in emergency funding for the CDFI Fund would allow more credit unions to access monies for specific programs; support the Health and Economic Recovery Omnibus Emergency Solutions Act (HEROES Act); support the inclusion of S.4159, the E-SIGN Modernization Act of 2020, in the relief package; credit unions, as not-for-profit cooperative institutions, should not be subject to the CECL standard; support a reduction in the level at which credit unions are considered well capitalized from a net-worth ratio of seven percent to six percent and adequately capitalized from six percent to five percent during the pandemic; reject any idea, even if well-meaning, that could place new hardships on credit unions; urges the Bureau of Consumer Financial Protection (Bureau or CFPB) to evaluate top credit union priorities, Delay Section 1071 Rulemaking, Electronic Disclosure Relief and Credit Card Accountability Responsibility and Disclosure Act of 2009 Act (CARD Act) Improvements, Temporarily Halt the Qualified Mortgage (QM) Rulemaking, Revise Home Mortgage Disclosure Act (HMDA) Rule and Reporting, Facilitate the London Interbank Offered Rate (LIBOR) Transition, Unfair, Deceptive, or Abusive Acts and Practices (UDAAP) Guidance and Rulemaking; urge NCUA provide relief to credit unions as they serve their members during the pandemic: Expanding Virtual Meetings, Managing Unexpected Share Growth, Additional Investment Opportunities, Capitalizing Interest on Loan Modifications, Adopting Broader Capital Reform, Finalizing an Efficient and Measured Budget; supports FinCEN defining an overall effective and reasonably designed AML program, including the explicit requirement for a risk-assessment; support automatic loan forgiveness for PPP loans under $150,000 and support any legislative efforts; support legislative efforts to amend the CARES Act to exclude Economic Injury Disaster Loans (EIDL) advance amounts from the calculation of loan forgiveness under the PPP; support initial 3508EZ form and the newly created 3508S form for loans under $50,000; support H.R. 8361, the EIDL Forgiveness Act; recommend a comment period of 90 days for all novel charter applications including the recent filings by Figure Bank for a national charter and Anchorage for a trust charter; TRACED Act; urged the Commission (FCC) not to impose additional restrictions on the existing exemption for informational calls placed to residential telephone numbers (Informational Calls Exemption); urges FinCEN to retain the current Recordkeeping and Travel Rule thresholds; supports the definition of money as proposed, which will resolve ambiguities surrounding applicability to convertible virtual currencies (CVCs); Thresholds for the Requirement to Collect, Retain, and Transmit Information Under the Recordkeeping and Travel Rules (Docket No.: FINCEN-2020-0002; RIN No.: 1506-AB41); Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support increase in size standards for North American Industry Classification System (NAICS) sectors related to finance and insurance, specifically NAICS code 522130 for credit unions; inclusion of S.4117, the Paycheck Protection Small Business Forgiveness Act; support the extensions of the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) and Troubled Debt Restructuring (TDR) provisions from the CARES Act; support focused clarification of regulatory expectations re: ECOA and Reg B; support HUDs codifying court rulings for disparate impact; support extension of CARES Act provisions: Section 1102: Paycheck Protection Program, Section 4012: Community Bank Leverage Ratio, Section 4014: Current Expected Credit Loss (CECL), Section 4008: Deposit Insurance, Section 4013: Troubled Debt Restructuring (TDR), Section 4016: NCUAs Central Liquidity Facility (CLF), Section 1110: Economic Injury Disaster Loan (EIDL) Program; Conference Report for H.R. 6395, the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021; express concern re: The Senates version of the FY 2021 NDAA, S.4049; supports efforts to provide additional emergency funding for CDFIs; outlines several recommendations to improve the efficiency of NCUA budget; bipartisan beneficial ownership and BSA/AML reform legislation - the Corporate Transparency Act and the COUNTER Act; Notice of Ex Parte Presentations, Rules & Regulations Implementing the Tel. Consumer Prot. Act of 1991, CG Docket No. 02-278; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support $25 billion in rental assistance to the Treasury Department to allocate to state and local governments, as well as extends the eviction moratorium; support NCUA modernizing the agencys derivatives rule, changing from a prescriptive approach to a more flexible, principles-based approach; support appreciates the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance ; H.R. 133, the Consolidated Appropriations Act of 2021

Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act

Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; Overhead Transfer Rate (OTR) methodology and operating fee schedule; support of the FCC's efforts to establish and implement exemptions to the TCPAs consent requirement for important information about fraudulent activity, data breaches and available protections, and money transfers; supportive of the FCCs proposal to not limit the number of calls made under the exemption; Comment on Annual Certification and Data Collection Report Form (ACR) and the Certification Transaction Level Report (CTLR), concerned about the reporting burden and cybersecurity risks associated with the proposed ACR and CTRL; support the certainty and regulatory flexibility afforded by many of the new and updated Interagency Questions and Answers regarding flood insurance; express concern the proposed Community Development Financial Institutions Program application creates many such barriers, which ultimately will make it more difficult and unlikely that credit unions will obtain and maintain CDFI-designation; urge the Federal Housing Finance Agency (FHFA) to evaluate top credit union regulatory priorities, Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the National Credit Union Administration (NCUA) to evaluate the priority issues and enact the requested policy modifications re: Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the U.S. Department of the Treasury (Treasury) along with the Financial Crimes Enforcement Network (FinCEN) and the Internal Revenue Service (IRS) to evaluate the top credit union priorities; express concern with Section 2885 of S.4049, which would expand access to nominal leases on military installations for banks; support for Division F, the Corporate Transparency Act of 2019 and Division G, the COUNTER Act of 2019, of H.R.6395, which would make critical improvements to our Bank Secrecy Act (BSA)/anti-money laundering (AML)/beneficial ownership regime; support of a simplified loan forgiveness process for PPP loans under a $150,000 threshold, such as proposed in H.R.7777/S.4117, the Paycheck Protection Small Business Forgiveness Act; support a second round of PPP loans to the hardest hit small businesses; extend the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) that were enacted in section 4016 of the CARES Act and to extend the provisions from section 4013 of the CARES Act dealing with Troubled Debt Restructuring (TDR); support H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020; support excluding EIDL advances from the PPP forgiveness calculation, as proposed by bipartisan legislation in the House, HR.8361, the EIDL Forgiveness Act; supports legislation, H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020, which would provide temporary relief from the credit union member business lending (MBL) cap; support increase funding for the CDFI and CDRLF programs. Providing $1 billion in emergency funding for the CDFI Fund would allow more credit unions to access monies for specific programs; support the Health and Economic Recovery Omnibus Emergency Solutions Act (HEROES Act); support the inclusion of S.4159, the E-SIGN Modernization Act of 2020, in the relief package; credit unions, as not-for-profit cooperative institutions, should not be subject to the CECL standard; support a reduction in the level at which credit unions are considered well capitalized from a net-worth ratio of seven percent to six percent and adequately capitalized from six percent to five percent during the pandemic; reject any idea, even if well-meaning, that could place new hardships on credit unions; urges the Bureau of Consumer Financial Protection (Bureau or CFPB) to evaluate top credit union priorities, Delay Section 1071 Rulemaking, Electronic Disclosure Relief and Credit Card Accountability Responsibility and Disclosure Act of 2009 Act (CARD Act) Improvements, Temporarily Halt the Qualified Mortgage (QM) Rulemaking, Revise Home Mortgage Disclosure Act (HMDA) Rule and Reporting, Facilitate the London Interbank Offered Rate (LIBOR) Transition, Unfair, Deceptive, or Abusive Acts and Practices (UDAAP) Guidance and Rulemaking; urge NCUA provide relief to credit unions as they serve their members during the pandemic: Expanding Virtual Meetings, Managing Unexpected Share Growth, Additional Investment Opportunities, Capitalizing Interest on Loan Modifications, Adopting Broader Capital Reform, Finalizing an Efficient and Measured Budget; supports FinCEN defining an overall effective and reasonably designed AML program, including the explicit requirement for a risk-assessment; support automatic loan forgiveness for PPP loans under $150,000 and support any legislative efforts; support legislative efforts to amend the CARES Act to exclude Economic Injury Disaster Loans (EIDL) advance amounts from the calculation of loan forgiveness under the PPP; support initial 3508EZ form and the newly created 3508S form for loans under $50,000; support H.R. 8361, the EIDL Forgiveness Act; recommend a comment period of 90 days for all novel charter applications including the recent filings by Figure Bank for a national charter and Anchorage for a trust charter; TRACED Act; urged the Commission (FCC) not to impose additional restrictions on the existing exemption for informational calls placed to residential telephone numbers (Informational Calls Exemption); urges FinCEN to retain the current Recordkeeping and Travel Rule thresholds; supports the definition of money as proposed, which will resolve ambiguities surrounding applicability to convertible virtual currencies (CVCs); Thresholds for the Requirement to Collect, Retain, and Transmit Information Under the Recordkeeping and Travel Rules (Docket No.: FINCEN-2020-0002; RIN No.: 1506-AB41); Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support increase in size standards for North American Industry Classification System (NAICS) sectors related to finance and insurance, specifically NAICS code 522130 for credit unions; inclusion of S.4117, the Paycheck Protection Small Business Forgiveness Act; support the extensions of the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) and Troubled Debt Restructuring (TDR) provisions from the CARES Act; support focused clarification of regulatory expectations re: ECOA and Reg B; support HUDs codifying court rulings for disparate impact; support extension of CARES Act provisions: Section 1102: Paycheck Protection Program, Section 4012: Community Bank Leverage Ratio, Section 4014: Current Expected Credit Loss (CECL), Section 4008: Deposit Insurance, Section 4013: Troubled Debt Restructuring (TDR), Section 4016: NCUAs Central Liquidity Facility (CLF), Section 1110: Economic Injury Disaster Loan (EIDL) Program; Conference Report for H.R. 6395, the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021; express concern re: The Senates version of the FY 2021 NDAA, S.4049; supports efforts to provide additional emergency funding for CDFIs; outlines several recommendations to improve the efficiency of NCUA budget; bipartisan beneficial ownership and BSA/AML reform legislation - the Corporate Transparency Act and the COUNTER Act; Notice of Ex Parte Presentations, Rules & Regulations Implementing the Tel. Consumer Prot. Act of 1991, CG Docket No. 02-278; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support $25 billion in rental assistance to the Treasury Department to allocate to state and local governments, as well as extends the eviction moratorium; support NCUA modernizing the agencys derivatives rule, changing from a prescriptive approach to a more flexible, principles-based approach; support appreciates the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance ; H.R. 133, the Consolidated Appropriations Act of 2021

Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act

Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act

Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act

Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act

Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act

Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; Overhead Transfer Rate (OTR) methodology and operating fee schedule; support of the FCC's efforts to establish and implement exemptions to the TCPAs consent requirement for important information about fraudulent activity, data breaches and available protections, and money transfers; supportive of the FCCs proposal to not limit the number of calls made under the exemption; Comment on Annual Certification and Data Collection Report Form (ACR) and the Certification Transaction Level Report (CTLR), concerned about the reporting burden and cybersecurity risks associated with the proposed ACR and CTRL; support the certainty and regulatory flexibility afforded by many of the new and updated Interagency Questions and Answers regarding flood insurance; express concern the proposed Community Development Financial Institutions Program application creates many such barriers, which ultimately will make it more difficult and unlikely that credit unions will obtain and maintain CDFI-designation; urge the Federal Housing Finance Agency (FHFA) to evaluate top credit union regulatory priorities, Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the National Credit Union Administration (NCUA) to evaluate the priority issues and enact the requested policy modifications re: Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the U.S. Department of the Treasury (Treasury) along with the Financial Crimes Enforcement Network (FinCEN) and the Internal Revenue Service (IRS) to evaluate the top credit union priorities; express concern with Section 2885 of S.4049, which would expand access to nominal leases on military installations for banks; support for Division F, the Corporate Transparency Act of 2019 and Division G, the COUNTER Act of 2019, of H.R.6395, which would make critical improvements to our Bank Secrecy Act (BSA)/anti-money laundering (AML)/beneficial ownership regime; support of a simplified loan forgiveness process for PPP loans under a $150,000 threshold, such as proposed in H.R.7777/S.4117, the Paycheck Protection Small Business Forgiveness Act; support a second round of PPP loans to the hardest hit small businesses; extend the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) that were enacted in section 4016 of the CARES Act and to extend the provisions from section 4013 of the CARES Act dealing with Troubled Debt Restructuring (TDR); support H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020; support excluding EIDL advances from the PPP forgiveness calculation, as proposed by bipartisan legislation in the House, HR.8361, the EIDL Forgiveness Act; supports legislation, H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020, which would provide temporary relief from the credit union member business lending (MBL) cap; support increase funding for the CDFI and CDRLF programs. Providing $1 billion in emergency funding for the CDFI Fund would allow more credit unions to access monies for specific programs; support the Health and Economic Recovery Omnibus Emergency Solutions Act (HEROES Act); support the inclusion of S.4159, the E-SIGN Modernization Act of 2020, in the relief package; credit unions, as not-for-profit cooperative institutions, should not be subject to the CECL standard; support a reduction in the level at which credit unions are considered well capitalized from a net-worth ratio of seven percent to six percent and adequately capitalized from six percent to five percent during the pandemic; reject any idea, even if well-meaning, that could place new hardships on credit unions; urges the Bureau of Consumer Financial Protection (Bureau or CFPB) to evaluate top credit union priorities, Delay Section 1071 Rulemaking, Electronic Disclosure Relief and Credit Card Accountability Responsibility and Disclosure Act of 2009 Act (CARD Act) Improvements, Temporarily Halt the Qualified Mortgage (QM) Rulemaking, Revise Home Mortgage Disclosure Act (HMDA) Rule and Reporting, Facilitate the London Interbank Offered Rate (LIBOR) Transition, Unfair, Deceptive, or Abusive Acts and Practices (UDAAP) Guidance and Rulemaking; urge NCUA provide relief to credit unions as they serve their members during the pandemic: Expanding Virtual Meetings, Managing Unexpected Share Growth, Additional Investment Opportunities, Capitalizing Interest on Loan Modifications, Adopting Broader Capital Reform, Finalizing an Efficient and Measured Budget; supports FinCEN defining an overall effective and reasonably designed AML program, including the explicit requirement for a risk-assessment; support automatic loan forgiveness for PPP loans under $150,000 and support any legislative efforts; support legislative efforts to amend the CARES Act to exclude Economic Injury Disaster Loans (EIDL) advance amounts from the calculation of loan forgiveness under the PPP; support initial 3508EZ form and the newly created 3508S form for loans under $50,000; support H.R. 8361, the EIDL Forgiveness Act; recommend a comment period of 90 days for all novel charter applications including the recent filings by Figure Bank for a national charter and Anchorage for a trust charter; TRACED Act; urged the Commission (FCC) not to impose additional restrictions on the existing exemption for informational calls placed to residential telephone numbers (Informational Calls Exemption); urges FinCEN to retain the current Recordkeeping and Travel Rule thresholds; supports the definition of money as proposed, which will resolve ambiguities surrounding applicability to convertible virtual currencies (CVCs); Thresholds for the Requirement to Collect, Retain, and Transmit Information Under the Recordkeeping and Travel Rules (Docket No.: FINCEN-2020-0002; RIN No.: 1506-AB41); Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support increase in size standards for North American Industry Classification System (NAICS) sectors related to finance and insurance, specifically NAICS code 522130 for credit unions; inclusion of S.4117, the Paycheck Protection Small Business Forgiveness Act; support the extensions of the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) and Troubled Debt Restructuring (TDR) provisions from the CARES Act; support focused clarification of regulatory expectations re: ECOA and Reg B; support HUDs codifying court rulings for disparate impact; support extension of CARES Act provisions: Section 1102: Paycheck Protection Program, Section 4012: Community Bank Leverage Ratio, Section 4014: Current Expected Credit Loss (CECL), Section 4008: Deposit Insurance, Section 4013: Troubled Debt Restructuring (TDR), Section 4016: NCUAs Central Liquidity Facility (CLF), Section 1110: Economic Injury Disaster Loan (EIDL) Program; Conference Report for H.R. 6395, the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021; express concern re: The Senates version of the FY 2021 NDAA, S.4049; supports efforts to provide additional emergency funding for CDFIs; outlines several recommendations to improve the efficiency of NCUA budget; bipartisan beneficial ownership and BSA/AML reform legislation - the Corporate Transparency Act and the COUNTER Act; Notice of Ex Parte Presentations, Rules & Regulations Implementing the Tel. Consumer Prot. Act of 1991, CG Docket No. 02-278; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support $25 billion in rental assistance to the Treasury Department to allocate to state and local governments, as well as extends the eviction moratorium; support NCUA modernizing the agencys derivatives rule, changing from a prescriptive approach to a more flexible, principles-based approach; support appreciates the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance ; H.R. 133, the Consolidated Appropriations Act of 2021

Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; Overhead Transfer Rate (OTR) methodology and operating fee schedule; support of the FCC's efforts to establish and implement exemptions to the TCPAs consent requirement for important information about fraudulent activity, data breaches and available protections, and money transfers; supportive of the FCCs proposal to not limit the number of calls made under the exemption; Comment on Annual Certification and Data Collection Report Form (ACR) and the Certification Transaction Level Report (CTLR), concerned about the reporting burden and cybersecurity risks associated with the proposed ACR and CTRL; support the certainty and regulatory flexibility afforded by many of the new and updated Interagency Questions and Answers regarding flood insurance; express concern the proposed Community Development Financial Institutions Program application creates many such barriers, which ultimately will make it more difficult and unlikely that credit unions will obtain and maintain CDFI-designation; urge the Federal Housing Finance Agency (FHFA) to evaluate top credit union regulatory priorities, Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the National Credit Union Administration (NCUA) to evaluate the priority issues and enact the requested policy modifications re: Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the U.S. Department of the Treasury (Treasury) along with the Financial Crimes Enforcement Network (FinCEN) and the Internal Revenue Service (IRS) to evaluate the top credit union priorities; express concern with Section 2885 of S.4049, which would expand access to nominal leases on military installations for banks; support for Division F, the Corporate Transparency Act of 2019 and Division G, the COUNTER Act of 2019, of H.R.6395, which would make critical improvements to our Bank Secrecy Act (BSA)/anti-money laundering (AML)/beneficial ownership regime; support of a simplified loan forgiveness process for PPP loans under a $150,000 threshold, such as proposed in H.R.7777/S.4117, the Paycheck Protection Small Business Forgiveness Act; support a second round of PPP loans to the hardest hit small businesses; extend the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) that were enacted in section 4016 of the CARES Act and to extend the provisions from section 4013 of the CARES Act dealing with Troubled Debt Restructuring (TDR); support H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020; support excluding EIDL advances from the PPP forgiveness calculation, as proposed by bipartisan legislation in the House, HR.8361, the EIDL Forgiveness Act; supports legislation, H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020, which would provide temporary relief from the credit union member business lending (MBL) cap; support increase funding for the CDFI and CDRLF programs. Providing $1 billion in emergency funding for the CDFI Fund would allow more credit unions to access monies for specific programs; support the Health and Economic Recovery Omnibus Emergency Solutions Act (HEROES Act); support the inclusion of S.4159, the E-SIGN Modernization Act of 2020, in the relief package; credit unions, as not-for-profit cooperative institutions, should not be subject to the CECL standard; support a reduction in the level at which credit unions are considered well capitalized from a net-worth ratio of seven percent to six percent and adequately capitalized from six percent to five percent during the pandemic; reject any idea, even if well-meaning, that could place new hardships on credit unions; urges the Bureau of Consumer Financial Protection (Bureau or CFPB) to evaluate top credit union priorities, Delay Section 1071 Rulemaking, Electronic Disclosure Relief and Credit Card Accountability Responsibility and Disclosure Act of 2009 Act (CARD Act) Improvements, Temporarily Halt the Qualified Mortgage (QM) Rulemaking, Revise Home Mortgage Disclosure Act (HMDA) Rule and Reporting, Facilitate the London Interbank Offered Rate (LIBOR) Transition, Unfair, Deceptive, or Abusive Acts and Practices (UDAAP) Guidance and Rulemaking; urge NCUA provide relief to credit unions as they serve their members during the pandemic: Expanding Virtual Meetings, Managing Unexpected Share Growth, Additional Investment Opportunities, Capitalizing Interest on Loan Modifications, Adopting Broader Capital Reform, Finalizing an Efficient and Measured Budget; supports FinCEN defining an overall effective and reasonably designed AML program, including the explicit requirement for a risk-assessment; support automatic loan forgiveness for PPP loans under $150,000 and support any legislative efforts; support legislative efforts to amend the CARES Act to exclude Economic Injury Disaster Loans (EIDL) advance amounts from the calculation of loan forgiveness under the PPP; support initial 3508EZ form and the newly created 3508S form for loans under $50,000; support H.R. 8361, the EIDL Forgiveness Act; recommend a comment period of 90 days for all novel charter applications including the recent filings by Figure Bank for a national charter and Anchorage for a trust charter; TRACED Act; urged the Commission (FCC) not to impose additional restrictions on the existing exemption for informational calls placed to residential telephone numbers (Informational Calls Exemption); urges FinCEN to retain the current Recordkeeping and Travel Rule thresholds; supports the definition of money as proposed, which will resolve ambiguities surrounding applicability to convertible virtual currencies (CVCs); Thresholds for the Requirement to Collect, Retain, and Transmit Information Under the Recordkeeping and Travel Rules (Docket No.: FINCEN-2020-0002; RIN No.: 1506-AB41); Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support increase in size standards for North American Industry Classification System (NAICS) sectors related to finance and insurance, specifically NAICS code 522130 for credit unions; inclusion of S.4117, the Paycheck Protection Small Business Forgiveness Act; support the extensions of the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) and Troubled Debt Restructuring (TDR) provisions from the CARES Act; support focused clarification of regulatory expectations re: ECOA and Reg B; support HUDs codifying court rulings for disparate impact; support extension of CARES Act provisions: Section 1102: Paycheck Protection Program, Section 4012: Community Bank Leverage Ratio, Section 4014: Current Expected Credit Loss (CECL), Section 4008: Deposit Insurance, Section 4013: Troubled Debt Restructuring (TDR), Section 4016: NCUAs Central Liquidity Facility (CLF), Section 1110: Economic Injury Disaster Loan (EIDL) Program; Conference Report for H.R. 6395, the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021; express concern re: The Senates version of the FY 2021 NDAA, S.4049; supports efforts to provide additional emergency funding for CDFIs; outlines several recommendations to improve the efficiency of NCUA budget; bipartisan beneficial ownership and BSA/AML reform legislation - the Corporate Transparency Act and the COUNTER Act; Notice of Ex Parte Presentations, Rules & Regulations Implementing the Tel. Consumer Prot. Act of 1991, CG Docket No. 02-278; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support $25 billion in rental assistance to the Treasury Department to allocate to state and local governments, as well as extends the eviction moratorium; support NCUA modernizing the agencys derivatives rule, changing from a prescriptive approach to a more flexible, principles-based approach; support appreciates the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance ; H.R. 133, the Consolidated Appropriations Act of 2021

Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act

Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; the CARES Act; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements- oppose fee structure increases; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements; GSEs should provide relief for CUs impacted by forbearances; raise 15-year maturity limit on certain CU loans; Establish an emergency flexible QM standard; Expand definition of Community FI in FHLB Act; expanding membership in FHLBs to include conduits should be explicitly prohibited; Limit liability for Essential Businesses; Assist associations in relief efforts related to COVID-19; do not eliminate courtesy pay; no blanket forbearance in COVID-19 relief; Increase PPP funding; Community Reinvestment Act; delay property tax assessments; FCC should issue an interim declaratory ruling or otherwise act on the Petition on an expedited basis related to autodialing; SBA to issue PPP guidance; H.R. 6550, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; minimize paper payments of Economic Impact payments; Treasury should ensure that all credit unions will be able to receive a payroll tax credit for providing paid sick leave related to COVID-19; support Chairman Hoods request to make changes to the CLF and PCA flexibility during COVID response; third-party vendor examination authority is unnecessary; examiner flexibility with PPP lending; inaccurate call labeling is harmful - provide effective redress; provide equitable access to small lenders for PPP loans and provide transparency related to pacing of applications; improvements to HEROES Act; Support for S. 3833, the Paycheck Protection Program Extension Act; NAFCU urges the NCUA Board to take up Overdraft Policy and approve; Automatic forgiveness of PPP loans under $150k; supportive of efforts to expand financial inclusion, but we are concerned FedAccounts could cause disruptions; oppose adding provision to NDAA that would give banks parity with CUs on military installations; strengthen and improve BSA/AML system while not overburdening CUs support adding Anti-Money Laundering Act of 2020 to NDAA; oppose H.R. 5332, the Protecting Your Credit Score Act; moving the U.S. currency to a federally-backed digital system will have unintended consequences that could affect the privacy of millions of Americans and erode the competitive viability of the U.S. banking system.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; the CARES Act; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements- oppose fee structure increases; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements; GSEs should provide relief for CUs impacted by forbearances; raise 15-year maturity limit on certain CU loans; Establish an emergency flexible QM standard; Expand definition of Community FI in FHLB Act; expanding membership in FHLBs to include conduits should be explicitly prohibited; Limit liability for Essential Businesses; Assist associations in relief efforts related to COVID-19; do not eliminate courtesy pay; no blanket forbearance in COVID-19 relief; Increase PPP funding; Community Reinvestment Act; delay property tax assessments; FCC should issue an interim declaratory ruling or otherwise act on the Petition on an expedited basis related to autodialing; SBA to issue PPP guidance; H.R. 6550, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; minimize paper payments of Economic Impact payments; Treasury should ensure that all credit unions will be able to receive a payroll tax credit for providing paid sick leave related to COVID-19; support Chairman Hoods request to make changes to the CLF and PCA flexibility during COVID response; third-party vendor examination authority is unnecessary; examiner flexibility with PPP lending; inaccurate call labeling is harmful - provide effective redress; provide equitable access to small lenders for PPP loans and provide transparency related to pacing of applications; improvements to HEROES Act; Support for S. 3833, the Paycheck Protection Program Extension Act; NAFCU urges the NCUA Board to take up Overdraft Policy and approve; Automatic forgiveness of PPP loans under $150k; supportive of efforts to expand financial inclusion, but we are concerned FedAccounts could cause disruptions; oppose adding provision to NDAA that would give banks parity with CUs on military installations; strengthen and improve BSA/AML system while not overburdening CUs support adding Anti-Money Laundering Act of 2020 to NDAA; oppose H.R. 5332, the Protecting Your Credit Score Act; moving the U.S. currency to a federally-backed digital system will have unintended consequences that could affect the privacy of millions of Americans and erode the competitive viability of the U.S. banking system.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements.

Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act

Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; the CARES Act; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements- oppose fee structure increases; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements; GSEs should provide relief for CUs impacted by forbearances; raise 15-year maturity limit on certain CU loans; Establish an emergency flexible QM standard; Expand definition of Community FI in FHLB Act; expanding membership in FHLBs to include conduits should be explicitly prohibited; Limit liability for Essential Businesses; Assist associations in relief efforts related to COVID-19; do not eliminate courtesy pay; no blanket forbearance in COVID-19 relief; Increase PPP funding; Community Reinvestment Act; delay property tax assessments; FCC should issue an interim declaratory ruling or otherwise act on the Petition on an expedited basis related to autodialing; SBA to issue PPP guidance; H.R. 6550, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; minimize paper payments of Economic Impact payments; Treasury should ensure that all credit unions will be able to receive a payroll tax credit for providing paid sick leave related to COVID-19; support Chairman Hoods request to make changes to the CLF and PCA flexibility during COVID response; third-party vendor examination authority is unnecessary; examiner flexibility with PPP lending; inaccurate call labeling is harmful - provide effective redress; provide equitable access to small lenders for PPP loans and provide transparency related to pacing of applications; improvements to HEROES Act; Support for S. 3833, the Paycheck Protection Program Extension Act; NAFCU urges the NCUA Board to take up Overdraft Policy and approve; Automatic forgiveness of PPP loans under $150k; supportive of efforts to expand financial inclusion, but we are concerned FedAccounts could cause disruptions; oppose adding provision to NDAA that would give banks parity with CUs on military installations; strengthen and improve BSA/AML system while not overburdening CUs support adding Anti-Money Laundering Act of 2020 to NDAA; oppose H.R. 5332, the Protecting Your Credit Score Act; moving the U.S. currency to a federally-backed digital system will have unintended consequences that could affect the privacy of millions of Americans and erode the competitive viability of the U.S. banking system.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; the CARES Act; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements- oppose fee structure increases; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements; GSEs should provide relief for CUs impacted by forbearances; raise 15-year maturity limit on certain CU loans; Establish an emergency flexible QM standard; Expand definition of Community FI in FHLB Act; expanding membership in FHLBs to include conduits should be explicitly prohibited; Limit liability for Essential Businesses; Assist associations in relief efforts related to COVID-19; do not eliminate courtesy pay; no blanket forbearance in COVID-19 relief; Increase PPP funding; Community Reinvestment Act; delay property tax assessments; FCC should issue an interim declaratory ruling or otherwise act on the Petition on an expedited basis related to autodialing; SBA to issue PPP guidance; H.R. 6550, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; minimize paper payments of Economic Impact payments; Treasury should ensure that all credit unions will be able to receive a payroll tax credit for providing paid sick leave related to COVID-19; support Chairman Hoods request to make changes to the CLF and PCA flexibility during COVID response; third-party vendor examination authority is unnecessary; examiner flexibility with PPP lending; inaccurate call labeling is harmful - provide effective redress; provide equitable access to small lenders for PPP loans and provide transparency related to pacing of applications; improvements to HEROES Act; Support for S. 3833, the Paycheck Protection Program Extension Act; NAFCU urges the NCUA Board to take up Overdraft Policy and approve; Automatic forgiveness of PPP loans under $150k; supportive of efforts to expand financial inclusion, but we are concerned FedAccounts could cause disruptions; oppose adding provision to NDAA that would give banks parity with CUs on military installations; strengthen and improve BSA/AML system while not overburdening CUs support adding Anti-Money Laundering Act of 2020 to NDAA; oppose H.R. 5332, the Protecting Your Credit Score Act; moving the U.S. currency to a federally-backed digital system will have unintended consequences that could affect the privacy of millions of Americans and erode the competitive viability of the U.S. banking system.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements.

Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; Overhead Transfer Rate (OTR) methodology and operating fee schedule; support of the FCC's efforts to establish and implement exemptions to the TCPAs consent requirement for important information about fraudulent activity, data breaches and available protections, and money transfers; supportive of the FCCs proposal to not limit the number of calls made under the exemption; Comment on Annual Certification and Data Collection Report Form (ACR) and the Certification Transaction Level Report (CTLR), concerned about the reporting burden and cybersecurity risks associated with the proposed ACR and CTRL; support the certainty and regulatory flexibility afforded by many of the new and updated Interagency Questions and Answers regarding flood insurance; express concern the proposed Community Development Financial Institutions Program application creates many such barriers, which ultimately will make it more difficult and unlikely that credit unions will obtain and maintain CDFI-designation; urge the Federal Housing Finance Agency (FHFA) to evaluate top credit union regulatory priorities, Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the National Credit Union Administration (NCUA) to evaluate the priority issues and enact the requested policy modifications re: Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the U.S. Department of the Treasury (Treasury) along with the Financial Crimes Enforcement Network (FinCEN) and the Internal Revenue Service (IRS) to evaluate the top credit union priorities; express concern with Section 2885 of S.4049, which would expand access to nominal leases on military installations for banks; support for Division F, the Corporate Transparency Act of 2019 and Division G, the COUNTER Act of 2019, of H.R.6395, which would make critical improvements to our Bank Secrecy Act (BSA)/anti-money laundering (AML)/beneficial ownership regime; support of a simplified loan forgiveness process for PPP loans under a $150,000 threshold, such as proposed in H.R.7777/S.4117, the Paycheck Protection Small Business Forgiveness Act; support a second round of PPP loans to the hardest hit small businesses; extend the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) that were enacted in section 4016 of the CARES Act and to extend the provisions from section 4013 of the CARES Act dealing with Troubled Debt Restructuring (TDR); support H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020; support excluding EIDL advances from the PPP forgiveness calculation, as proposed by bipartisan legislation in the House, HR.8361, the EIDL Forgiveness Act; supports legislation, H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020, which would provide temporary relief from the credit union member business lending (MBL) cap; support increase funding for the CDFI and CDRLF programs. Providing $1 billion in emergency funding for the CDFI Fund would allow more credit unions to access monies for specific programs; support the Health and Economic Recovery Omnibus Emergency Solutions Act (HEROES Act); support the inclusion of S.4159, the E-SIGN Modernization Act of 2020, in the relief package; credit unions, as not-for-profit cooperative institutions, should not be subject to the CECL standard; support a reduction in the level at which credit unions are considered well capitalized from a net-worth ratio of seven percent to six percent and adequately capitalized from six percent to five percent during the pandemic; reject any idea, even if well-meaning, that could place new hardships on credit unions; urges the Bureau of Consumer Financial Protection (Bureau or CFPB) to evaluate top credit union priorities, Delay Section 1071 Rulemaking, Electronic Disclosure Relief and Credit Card Accountability Responsibility and Disclosure Act of 2009 Act (CARD Act) Improvements, Temporarily Halt the Qualified Mortgage (QM) Rulemaking, Revise Home Mortgage Disclosure Act (HMDA) Rule and Reporting, Facilitate the London Interbank Offered Rate (LIBOR) Transition, Unfair, Deceptive, or Abusive Acts and Practices (UDAAP) Guidance and Rulemaking; urge NCUA provide relief to credit unions as they serve their members during the pandemic: Expanding Virtual Meetings, Managing Unexpected Share Growth, Additional Investment Opportunities, Capitalizing Interest on Loan Modifications, Adopting Broader Capital Reform, Finalizing an Efficient and Measured Budget; supports FinCEN defining an overall effective and reasonably designed AML program, including the explicit requirement for a risk-assessment; support automatic loan forgiveness for PPP loans under $150,000 and support any legislative efforts; support legislative efforts to amend the CARES Act to exclude Economic Injury Disaster Loans (EIDL) advance amounts from the calculation of loan forgiveness under the PPP; support initial 3508EZ form and the newly created 3508S form for loans under $50,000; support H.R. 8361, the EIDL Forgiveness Act; recommend a comment period of 90 days for all novel charter applications including the recent filings by Figure Bank for a national charter and Anchorage for a trust charter; TRACED Act; urged the Commission (FCC) not to impose additional restrictions on the existing exemption for informational calls placed to residential telephone numbers (Informational Calls Exemption); urges FinCEN to retain the current Recordkeeping and Travel Rule thresholds; supports the definition of money as proposed, which will resolve ambiguities surrounding applicability to convertible virtual currencies (CVCs); Thresholds for the Requirement to Collect, Retain, and Transmit Information Under the Recordkeeping and Travel Rules (Docket No.: FINCEN-2020-0002; RIN No.: 1506-AB41); Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support increase in size standards for North American Industry Classification System (NAICS) sectors related to finance and insurance, specifically NAICS code 522130 for credit unions; inclusion of S.4117, the Paycheck Protection Small Business Forgiveness Act; support the extensions of the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) and Troubled Debt Restructuring (TDR) provisions from the CARES Act; support focused clarification of regulatory expectations re: ECOA and Reg B; support HUDs codifying court rulings for disparate impact; support extension of CARES Act provisions: Section 1102: Paycheck Protection Program, Section 4012: Community Bank Leverage Ratio, Section 4014: Current Expected Credit Loss (CECL), Section 4008: Deposit Insurance, Section 4013: Troubled Debt Restructuring (TDR), Section 4016: NCUAs Central Liquidity Facility (CLF), Section 1110: Economic Injury Disaster Loan (EIDL) Program; Conference Report for H.R. 6395, the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021; express concern re: The Senates version of the FY 2021 NDAA, S.4049; supports efforts to provide additional emergency funding for CDFIs; outlines several recommendations to improve the efficiency of NCUA budget; bipartisan beneficial ownership and BSA/AML reform legislation - the Corporate Transparency Act and the COUNTER Act; Notice of Ex Parte Presentations, Rules & Regulations Implementing the Tel. Consumer Prot. Act of 1991, CG Docket No. 02-278; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support $25 billion in rental assistance to the Treasury Department to allocate to state and local governments, as well as extends the eviction moratorium; support NCUA modernizing the agencys derivatives rule, changing from a prescriptive approach to a more flexible, principles-based approach; support appreciates the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance ; H.R. 133, the Consolidated Appropriations Act of 2021

Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; Overhead Transfer Rate (OTR) methodology and operating fee schedule; support of the FCC's efforts to establish and implement exemptions to the TCPAs consent requirement for important information about fraudulent activity, data breaches and available protections, and money transfers; supportive of the FCCs proposal to not limit the number of calls made under the exemption; Comment on Annual Certification and Data Collection Report Form (ACR) and the Certification Transaction Level Report (CTLR), concerned about the reporting burden and cybersecurity risks associated with the proposed ACR and CTRL; support the certainty and regulatory flexibility afforded by many of the new and updated Interagency Questions and Answers regarding flood insurance; express concern the proposed Community Development Financial Institutions Program application creates many such barriers, which ultimately will make it more difficult and unlikely that credit unions will obtain and maintain CDFI-designation; urge the Federal Housing Finance Agency (FHFA) to evaluate top credit union regulatory priorities, Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the National Credit Union Administration (NCUA) to evaluate the priority issues and enact the requested policy modifications re: Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the U.S. Department of the Treasury (Treasury) along with the Financial Crimes Enforcement Network (FinCEN) and the Internal Revenue Service (IRS) to evaluate the top credit union priorities; express concern with Section 2885 of S.4049, which would expand access to nominal leases on military installations for banks; support for Division F, the Corporate Transparency Act of 2019 and Division G, the COUNTER Act of 2019, of H.R.6395, which would make critical improvements to our Bank Secrecy Act (BSA)/anti-money laundering (AML)/beneficial ownership regime; support of a simplified loan forgiveness process for PPP loans under a $150,000 threshold, such as proposed in H.R.7777/S.4117, the Paycheck Protection Small Business Forgiveness Act; support a second round of PPP loans to the hardest hit small businesses; extend the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) that were enacted in section 4016 of the CARES Act and to extend the provisions from section 4013 of the CARES Act dealing with Troubled Debt Restructuring (TDR); support H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020; support excluding EIDL advances from the PPP forgiveness calculation, as proposed by bipartisan legislation in the House, HR.8361, the EIDL Forgiveness Act; supports legislation, H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020, which would provide temporary relief from the credit union member business lending (MBL) cap; support increase funding for the CDFI and CDRLF programs. Providing $1 billion in emergency funding for the CDFI Fund would allow more credit unions to access monies for specific programs; support the Health and Economic Recovery Omnibus Emergency Solutions Act (HEROES Act); support the inclusion of S.4159, the E-SIGN Modernization Act of 2020, in the relief package; credit unions, as not-for-profit cooperative institutions, should not be subject to the CECL standard; support a reduction in the level at which credit unions are considered well capitalized from a net-worth ratio of seven percent to six percent and adequately capitalized from six percent to five percent during the pandemic; reject any idea, even if well-meaning, that could place new hardships on credit unions; urges the Bureau of Consumer Financial Protection (Bureau or CFPB) to evaluate top credit union priorities, Delay Section 1071 Rulemaking, Electronic Disclosure Relief and Credit Card Accountability Responsibility and Disclosure Act of 2009 Act (CARD Act) Improvements, Temporarily Halt the Qualified Mortgage (QM) Rulemaking, Revise Home Mortgage Disclosure Act (HMDA) Rule and Reporting, Facilitate the London Interbank Offered Rate (LIBOR) Transition, Unfair, Deceptive, or Abusive Acts and Practices (UDAAP) Guidance and Rulemaking; urge NCUA provide relief to credit unions as they serve their members during the pandemic: Expanding Virtual Meetings, Managing Unexpected Share Growth, Additional Investment Opportunities, Capitalizing Interest on Loan Modifications, Adopting Broader Capital Reform, Finalizing an Efficient and Measured Budget; supports FinCEN defining an overall effective and reasonably designed AML program, including the explicit requirement for a risk-assessment; support automatic loan forgiveness for PPP loans under $150,000 and support any legislative efforts; support legislative efforts to amend the CARES Act to exclude Economic Injury Disaster Loans (EIDL) advance amounts from the calculation of loan forgiveness under the PPP; support initial 3508EZ form and the newly created 3508S form for loans under $50,000; support H.R. 8361, the EIDL Forgiveness Act; recommend a comment period of 90 days for all novel charter applications including the recent filings by Figure Bank for a national charter and Anchorage for a trust charter; TRACED Act; urged the Commission (FCC) not to impose additional restrictions on the existing exemption for informational calls placed to residential telephone numbers (Informational Calls Exemption); urges FinCEN to retain the current Recordkeeping and Travel Rule thresholds; supports the definition of money as proposed, which will resolve ambiguities surrounding applicability to convertible virtual currencies (CVCs); Thresholds for the Requirement to Collect, Retain, and Transmit Information Under the Recordkeeping and Travel Rules (Docket No.: FINCEN-2020-0002; RIN No.: 1506-AB41); Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support increase in size standards for North American Industry Classification System (NAICS) sectors related to finance and insurance, specifically NAICS code 522130 for credit unions; inclusion of S.4117, the Paycheck Protection Small Business Forgiveness Act; support the extensions of the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) and Troubled Debt Restructuring (TDR) provisions from the CARES Act; support focused clarification of regulatory expectations re: ECOA and Reg B; support HUDs codifying court rulings for disparate impact; support extension of CARES Act provisions: Section 1102: Paycheck Protection Program, Section 4012: Community Bank Leverage Ratio, Section 4014: Current Expected Credit Loss (CECL), Section 4008: Deposit Insurance, Section 4013: Troubled Debt Restructuring (TDR), Section 4016: NCUAs Central Liquidity Facility (CLF), Section 1110: Economic Injury Disaster Loan (EIDL) Program; Conference Report for H.R. 6395, the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021; express concern re: The Senates version of the FY 2021 NDAA, S.4049; supports efforts to provide additional emergency funding for CDFIs; outlines several recommendations to improve the efficiency of NCUA budget; bipartisan beneficial ownership and BSA/AML reform legislation - the Corporate Transparency Act and the COUNTER Act; Notice of Ex Parte Presentations, Rules & Regulations Implementing the Tel. Consumer Prot. Act of 1991, CG Docket No. 02-278; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support $25 billion in rental assistance to the Treasury Department to allocate to state and local governments, as well as extends the eviction moratorium; support NCUA modernizing the agencys derivatives rule, changing from a prescriptive approach to a more flexible, principles-based approach; support appreciates the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance ; H.R. 133, the Consolidated Appropriations Act of 2021

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; the CARES Act; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements- oppose fee structure increases; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements; GSEs should provide relief for CUs impacted by forbearances; raise 15-year maturity limit on certain CU loans; Establish an emergency flexible QM standard; Expand definition of Community FI in FHLB Act; expanding membership in FHLBs to include conduits should be explicitly prohibited; Limit liability for Essential Businesses; Assist associations in relief efforts related to COVID-19; do not eliminate courtesy pay; no blanket forbearance in COVID-19 relief; Increase PPP funding; Community Reinvestment Act; delay property tax assessments; FCC should issue an interim declaratory ruling or otherwise act on the Petition on an expedited basis related to autodialing; SBA to issue PPP guidance; H.R. 6550, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; minimize paper payments of Economic Impact payments; Treasury should ensure that all credit unions will be able to receive a payroll tax credit for providing paid sick leave related to COVID-19; support Chairman Hoods request to make changes to the CLF and PCA flexibility during COVID response; third-party vendor examination authority is unnecessary; examiner flexibility with PPP lending; inaccurate call labeling is harmful - provide effective redress; provide equitable access to small lenders for PPP loans and provide transparency related to pacing of applications; improvements to HEROES Act; Support for S. 3833, the Paycheck Protection Program Extension Act; NAFCU urges the NCUA Board to take up Overdraft Policy and approve; Automatic forgiveness of PPP loans under $150k; supportive of efforts to expand financial inclusion, but we are concerned FedAccounts could cause disruptions; oppose adding provision to NDAA that would give banks parity with CUs on military installations; strengthen and improve BSA/AML system while not overburdening CUs support adding Anti-Money Laundering Act of 2020 to NDAA; oppose H.R. 5332, the Protecting Your Credit Score Act; moving the U.S. currency to a federally-backed digital system will have unintended consequences that could affect the privacy of millions of Americans and erode the competitive viability of the U.S. banking system.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; the CARES Act; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements- oppose fee structure increases; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements; GSEs should provide relief for CUs impacted by forbearances; raise 15-year maturity limit on certain CU loans; Establish an emergency flexible QM standard; Expand definition of Community FI in FHLB Act; expanding membership in FHLBs to include conduits should be explicitly prohibited; Limit liability for Essential Businesses; Assist associations in relief efforts related to COVID-19; do not eliminate courtesy pay; no blanket forbearance in COVID-19 relief; Increase PPP funding; Community Reinvestment Act; delay property tax assessments; FCC should issue an interim declaratory ruling or otherwise act on the Petition on an expedited basis related to autodialing; SBA to issue PPP guidance; H.R. 6550, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; minimize paper payments of Economic Impact payments; Treasury should ensure that all credit unions will be able to receive a payroll tax credit for providing paid sick leave related to COVID-19; support Chairman Hoods request to make changes to the CLF and PCA flexibility during COVID response; third-party vendor examination authority is unnecessary; examiner flexibility with PPP lending; inaccurate call labeling is harmful - provide effective redress; provide equitable access to small lenders for PPP loans and provide transparency related to pacing of applications; improvements to HEROES Act; Support for S. 3833, the Paycheck Protection Program Extension Act; NAFCU urges the NCUA Board to take up Overdraft Policy and approve; Automatic forgiveness of PPP loans under $150k; supportive of efforts to expand financial inclusion, but we are concerned FedAccounts could cause disruptions; oppose adding provision to NDAA that would give banks parity with CUs on military installations; strengthen and improve BSA/AML system while not overburdening CUs support adding Anti-Money Laundering Act of 2020 to NDAA; oppose H.R. 5332, the Protecting Your Credit Score Act; moving the U.S. currency to a federally-backed digital system will have unintended consequences that could affect the privacy of millions of Americans and erode the competitive viability of the U.S. banking system.

Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; Overhead Transfer Rate (OTR) methodology and operating fee schedule; support of the FCC's efforts to establish and implement exemptions to the TCPAs consent requirement for important information about fraudulent activity, data breaches and available protections, and money transfers; supportive of the FCCs proposal to not limit the number of calls made under the exemption; Comment on Annual Certification and Data Collection Report Form (ACR) and the Certification Transaction Level Report (CTLR), concerned about the reporting burden and cybersecurity risks associated with the proposed ACR and CTRL; support the certainty and regulatory flexibility afforded by many of the new and updated Interagency Questions and Answers regarding flood insurance; express concern the proposed Community Development Financial Institutions Program application creates many such barriers, which ultimately will make it more difficult and unlikely that credit unions will obtain and maintain CDFI-designation; urge the Federal Housing Finance Agency (FHFA) to evaluate top credit union regulatory priorities, Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the National Credit Union Administration (NCUA) to evaluate the priority issues and enact the requested policy modifications re: Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the U.S. Department of the Treasury (Treasury) along with the Financial Crimes Enforcement Network (FinCEN) and the Internal Revenue Service (IRS) to evaluate the top credit union priorities; express concern with Section 2885 of S.4049, which would expand access to nominal leases on military installations for banks; support for Division F, the Corporate Transparency Act of 2019 and Division G, the COUNTER Act of 2019, of H.R.6395, which would make critical improvements to our Bank Secrecy Act (BSA)/anti-money laundering (AML)/beneficial ownership regime; support of a simplified loan forgiveness process for PPP loans under a $150,000 threshold, such as proposed in H.R.7777/S.4117, the Paycheck Protection Small Business Forgiveness Act; support a second round of PPP loans to the hardest hit small businesses; extend the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) that were enacted in section 4016 of the CARES Act and to extend the provisions from section 4013 of the CARES Act dealing with Troubled Debt Restructuring (TDR); support H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020; support excluding EIDL advances from the PPP forgiveness calculation, as proposed by bipartisan legislation in the House, HR.8361, the EIDL Forgiveness Act; supports legislation, H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020, which would provide temporary relief from the credit union member business lending (MBL) cap; support increase funding for the CDFI and CDRLF programs. Providing $1 billion in emergency funding for the CDFI Fund would allow more credit unions to access monies for specific programs; support the Health and Economic Recovery Omnibus Emergency Solutions Act (HEROES Act); support the inclusion of S.4159, the E-SIGN Modernization Act of 2020, in the relief package; credit unions, as not-for-profit cooperative institutions, should not be subject to the CECL standard; support a reduction in the level at which credit unions are considered well capitalized from a net-worth ratio of seven percent to six percent and adequately capitalized from six percent to five percent during the pandemic; reject any idea, even if well-meaning, that could place new hardships on credit unions; urges the Bureau of Consumer Financial Protection (Bureau or CFPB) to evaluate top credit union priorities, Delay Section 1071 Rulemaking, Electronic Disclosure Relief and Credit Card Accountability Responsibility and Disclosure Act of 2009 Act (CARD Act) Improvements, Temporarily Halt the Qualified Mortgage (QM) Rulemaking, Revise Home Mortgage Disclosure Act (HMDA) Rule and Reporting, Facilitate the London Interbank Offered Rate (LIBOR) Transition, Unfair, Deceptive, or Abusive Acts and Practices (UDAAP) Guidance and Rulemaking; urge NCUA provide relief to credit unions as they serve their members during the pandemic: Expanding Virtual Meetings, Managing Unexpected Share Growth, Additional Investment Opportunities, Capitalizing Interest on Loan Modifications, Adopting Broader Capital Reform, Finalizing an Efficient and Measured Budget; supports FinCEN defining an overall effective and reasonably designed AML program, including the explicit requirement for a risk-assessment; support automatic loan forgiveness for PPP loans under $150,000 and support any legislative efforts; support legislative efforts to amend the CARES Act to exclude Economic Injury Disaster Loans (EIDL) advance amounts from the calculation of loan forgiveness under the PPP; support initial 3508EZ form and the newly created 3508S form for loans under $50,000; support H.R. 8361, the EIDL Forgiveness Act; recommend a comment period of 90 days for all novel charter applications including the recent filings by Figure Bank for a national charter and Anchorage for a trust charter; TRACED Act; urged the Commission (FCC) not to impose additional restrictions on the existing exemption for informational calls placed to residential telephone numbers (Informational Calls Exemption); urges FinCEN to retain the current Recordkeeping and Travel Rule thresholds; supports the definition of money as proposed, which will resolve ambiguities surrounding applicability to convertible virtual currencies (CVCs); Thresholds for the Requirement to Collect, Retain, and Transmit Information Under the Recordkeeping and Travel Rules (Docket No.: FINCEN-2020-0002; RIN No.: 1506-AB41); Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support increase in size standards for North American Industry Classification System (NAICS) sectors related to finance and insurance, specifically NAICS code 522130 for credit unions; inclusion of S.4117, the Paycheck Protection Small Business Forgiveness Act; support the extensions of the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) and Troubled Debt Restructuring (TDR) provisions from the CARES Act; support focused clarification of regulatory expectations re: ECOA and Reg B; support HUDs codifying court rulings for disparate impact; support extension of CARES Act provisions: Section 1102: Paycheck Protection Program, Section 4012: Community Bank Leverage Ratio, Section 4014: Current Expected Credit Loss (CECL), Section 4008: Deposit Insurance, Section 4013: Troubled Debt Restructuring (TDR), Section 4016: NCUAs Central Liquidity Facility (CLF), Section 1110: Economic Injury Disaster Loan (EIDL) Program; Conference Report for H.R. 6395, the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021; express concern re: The Senates version of the FY 2021 NDAA, S.4049; supports efforts to provide additional emergency funding for CDFIs; outlines several recommendations to improve the efficiency of NCUA budget; bipartisan beneficial ownership and BSA/AML reform legislation - the Corporate Transparency Act and the COUNTER Act; Notice of Ex Parte Presentations, Rules & Regulations Implementing the Tel. Consumer Prot. Act of 1991, CG Docket No. 02-278; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support $25 billion in rental assistance to the Treasury Department to allocate to state and local governments, as well as extends the eviction moratorium; support NCUA modernizing the agencys derivatives rule, changing from a prescriptive approach to a more flexible, principles-based approach; support appreciates the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance ; H.R. 133, the Consolidated Appropriations Act of 2021

Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act

Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; Overhead Transfer Rate (OTR) methodology and operating fee schedule; support of the FCC's efforts to establish and implement exemptions to the TCPAs consent requirement for important information about fraudulent activity, data breaches and available protections, and money transfers; supportive of the FCCs proposal to not limit the number of calls made under the exemption; Comment on Annual Certification and Data Collection Report Form (ACR) and the Certification Transaction Level Report (CTLR), concerned about the reporting burden and cybersecurity risks associated with the proposed ACR and CTRL; support the certainty and regulatory flexibility afforded by many of the new and updated Interagency Questions and Answers regarding flood insurance; express concern the proposed Community Development Financial Institutions Program application creates many such barriers, which ultimately will make it more difficult and unlikely that credit unions will obtain and maintain CDFI-designation; urge the Federal Housing Finance Agency (FHFA) to evaluate top credit union regulatory priorities, Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the National Credit Union Administration (NCUA) to evaluate the priority issues and enact the requested policy modifications re: Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the U.S. Department of the Treasury (Treasury) along with the Financial Crimes Enforcement Network (FinCEN) and the Internal Revenue Service (IRS) to evaluate the top credit union priorities; express concern with Section 2885 of S.4049, which would expand access to nominal leases on military installations for banks; support for Division F, the Corporate Transparency Act of 2019 and Division G, the COUNTER Act of 2019, of H.R.6395, which would make critical improvements to our Bank Secrecy Act (BSA)/anti-money laundering (AML)/beneficial ownership regime; support of a simplified loan forgiveness process for PPP loans under a $150,000 threshold, such as proposed in H.R.7777/S.4117, the Paycheck Protection Small Business Forgiveness Act; support a second round of PPP loans to the hardest hit small businesses; extend the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) that were enacted in section 4016 of the CARES Act and to extend the provisions from section 4013 of the CARES Act dealing with Troubled Debt Restructuring (TDR); support H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020; support excluding EIDL advances from the PPP forgiveness calculation, as proposed by bipartisan legislation in the House, HR.8361, the EIDL Forgiveness Act; supports legislation, H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020, which would provide temporary relief from the credit union member business lending (MBL) cap; support increase funding for the CDFI and CDRLF programs. Providing $1 billion in emergency funding for the CDFI Fund would allow more credit unions to access monies for specific programs; support the Health and Economic Recovery Omnibus Emergency Solutions Act (HEROES Act); support the inclusion of S.4159, the E-SIGN Modernization Act of 2020, in the relief package; credit unions, as not-for-profit cooperative institutions, should not be subject to the CECL standard; support a reduction in the level at which credit unions are considered well capitalized from a net-worth ratio of seven percent to six percent and adequately capitalized from six percent to five percent during the pandemic; reject any idea, even if well-meaning, that could place new hardships on credit unions; urges the Bureau of Consumer Financial Protection (Bureau or CFPB) to evaluate top credit union priorities, Delay Section 1071 Rulemaking, Electronic Disclosure Relief and Credit Card Accountability Responsibility and Disclosure Act of 2009 Act (CARD Act) Improvements, Temporarily Halt the Qualified Mortgage (QM) Rulemaking, Revise Home Mortgage Disclosure Act (HMDA) Rule and Reporting, Facilitate the London Interbank Offered Rate (LIBOR) Transition, Unfair, Deceptive, or Abusive Acts and Practices (UDAAP) Guidance and Rulemaking; urge NCUA provide relief to credit unions as they serve their members during the pandemic: Expanding Virtual Meetings, Managing Unexpected Share Growth, Additional Investment Opportunities, Capitalizing Interest on Loan Modifications, Adopting Broader Capital Reform, Finalizing an Efficient and Measured Budget; supports FinCEN defining an overall effective and reasonably designed AML program, including the explicit requirement for a risk-assessment; support automatic loan forgiveness for PPP loans under $150,000 and support any legislative efforts; support legislative efforts to amend the CARES Act to exclude Economic Injury Disaster Loans (EIDL) advance amounts from the calculation of loan forgiveness under the PPP; support initial 3508EZ form and the newly created 3508S form for loans under $50,000; support H.R. 8361, the EIDL Forgiveness Act; recommend a comment period of 90 days for all novel charter applications including the recent filings by Figure Bank for a national charter and Anchorage for a trust charter; TRACED Act; urged the Commission (FCC) not to impose additional restrictions on the existing exemption for informational calls placed to residential telephone numbers (Informational Calls Exemption); urges FinCEN to retain the current Recordkeeping and Travel Rule thresholds; supports the definition of money as proposed, which will resolve ambiguities surrounding applicability to convertible virtual currencies (CVCs); Thresholds for the Requirement to Collect, Retain, and Transmit Information Under the Recordkeeping and Travel Rules (Docket No.: FINCEN-2020-0002; RIN No.: 1506-AB41); Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support increase in size standards for North American Industry Classification System (NAICS) sectors related to finance and insurance, specifically NAICS code 522130 for credit unions; inclusion of S.4117, the Paycheck Protection Small Business Forgiveness Act; support the extensions of the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) and Troubled Debt Restructuring (TDR) provisions from the CARES Act; support focused clarification of regulatory expectations re: ECOA and Reg B; support HUDs codifying court rulings for disparate impact; support extension of CARES Act provisions: Section 1102: Paycheck Protection Program, Section 4012: Community Bank Leverage Ratio, Section 4014: Current Expected Credit Loss (CECL), Section 4008: Deposit Insurance, Section 4013: Troubled Debt Restructuring (TDR), Section 4016: NCUAs Central Liquidity Facility (CLF), Section 1110: Economic Injury Disaster Loan (EIDL) Program; Conference Report for H.R. 6395, the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021; express concern re: The Senates version of the FY 2021 NDAA, S.4049; supports efforts to provide additional emergency funding for CDFIs; outlines several recommendations to improve the efficiency of NCUA budget; bipartisan beneficial ownership and BSA/AML reform legislation - the Corporate Transparency Act and the COUNTER Act; Notice of Ex Parte Presentations, Rules & Regulations Implementing the Tel. Consumer Prot. Act of 1991, CG Docket No. 02-278; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support $25 billion in rental assistance to the Treasury Department to allocate to state and local governments, as well as extends the eviction moratorium; support NCUA modernizing the agencys derivatives rule, changing from a prescriptive approach to a more flexible, principles-based approach; support appreciates the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance ; H.R. 133, the Consolidated Appropriations Act of 2021

Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act

Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; Overhead Transfer Rate (OTR) methodology and operating fee schedule; support of the FCC's efforts to establish and implement exemptions to the TCPAs consent requirement for important information about fraudulent activity, data breaches and available protections, and money transfers; supportive of the FCCs proposal to not limit the number of calls made under the exemption; Comment on Annual Certification and Data Collection Report Form (ACR) and the Certification Transaction Level Report (CTLR), concerned about the reporting burden and cybersecurity risks associated with the proposed ACR and CTRL; support the certainty and regulatory flexibility afforded by many of the new and updated Interagency Questions and Answers regarding flood insurance; express concern the proposed Community Development Financial Institutions Program application creates many such barriers, which ultimately will make it more difficult and unlikely that credit unions will obtain and maintain CDFI-designation; urge the Federal Housing Finance Agency (FHFA) to evaluate top credit union regulatory priorities, Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the National Credit Union Administration (NCUA) to evaluate the priority issues and enact the requested policy modifications re: Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the U.S. Department of the Treasury (Treasury) along with the Financial Crimes Enforcement Network (FinCEN) and the Internal Revenue Service (IRS) to evaluate the top credit union priorities; express concern with Section 2885 of S.4049, which would expand access to nominal leases on military installations for banks; support for Division F, the Corporate Transparency Act of 2019 and Division G, the COUNTER Act of 2019, of H.R.6395, which would make critical improvements to our Bank Secrecy Act (BSA)/anti-money laundering (AML)/beneficial ownership regime; support of a simplified loan forgiveness process for PPP loans under a $150,000 threshold, such as proposed in H.R.7777/S.4117, the Paycheck Protection Small Business Forgiveness Act; support a second round of PPP loans to the hardest hit small businesses; extend the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) that were enacted in section 4016 of the CARES Act and to extend the provisions from section 4013 of the CARES Act dealing with Troubled Debt Restructuring (TDR); support H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020; support excluding EIDL advances from the PPP forgiveness calculation, as proposed by bipartisan legislation in the House, HR.8361, the EIDL Forgiveness Act; supports legislation, H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020, which would provide temporary relief from the credit union member business lending (MBL) cap; support increase funding for the CDFI and CDRLF programs. Providing $1 billion in emergency funding for the CDFI Fund would allow more credit unions to access monies for specific programs; support the Health and Economic Recovery Omnibus Emergency Solutions Act (HEROES Act); support the inclusion of S.4159, the E-SIGN Modernization Act of 2020, in the relief package; credit unions, as not-for-profit cooperative institutions, should not be subject to the CECL standard; support a reduction in the level at which credit unions are considered well capitalized from a net-worth ratio of seven percent to six percent and adequately capitalized from six percent to five percent during the pandemic; reject any idea, even if well-meaning, that could place new hardships on credit unions; urges the Bureau of Consumer Financial Protection (Bureau or CFPB) to evaluate top credit union priorities, Delay Section 1071 Rulemaking, Electronic Disclosure Relief and Credit Card Accountability Responsibility and Disclosure Act of 2009 Act (CARD Act) Improvements, Temporarily Halt the Qualified Mortgage (QM) Rulemaking, Revise Home Mortgage Disclosure Act (HMDA) Rule and Reporting, Facilitate the London Interbank Offered Rate (LIBOR) Transition, Unfair, Deceptive, or Abusive Acts and Practices (UDAAP) Guidance and Rulemaking; urge NCUA provide relief to credit unions as they serve their members during the pandemic: Expanding Virtual Meetings, Managing Unexpected Share Growth, Additional Investment Opportunities, Capitalizing Interest on Loan Modifications, Adopting Broader Capital Reform, Finalizing an Efficient and Measured Budget; supports FinCEN defining an overall effective and reasonably designed AML program, including the explicit requirement for a risk-assessment; support automatic loan forgiveness for PPP loans under $150,000 and support any legislative efforts; support legislative efforts to amend the CARES Act to exclude Economic Injury Disaster Loans (EIDL) advance amounts from the calculation of loan forgiveness under the PPP; support initial 3508EZ form and the newly created 3508S form for loans under $50,000; support H.R. 8361, the EIDL Forgiveness Act; recommend a comment period of 90 days for all novel charter applications including the recent filings by Figure Bank for a national charter and Anchorage for a trust charter; TRACED Act; urged the Commission (FCC) not to impose additional restrictions on the existing exemption for informational calls placed to residential telephone numbers (Informational Calls Exemption); urges FinCEN to retain the current Recordkeeping and Travel Rule thresholds; supports the definition of money as proposed, which will resolve ambiguities surrounding applicability to convertible virtual currencies (CVCs); Thresholds for the Requirement to Collect, Retain, and Transmit Information Under the Recordkeeping and Travel Rules (Docket No.: FINCEN-2020-0002; RIN No.: 1506-AB41); Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support increase in size standards for North American Industry Classification System (NAICS) sectors related to finance and insurance, specifically NAICS code 522130 for credit unions; inclusion of S.4117, the Paycheck Protection Small Business Forgiveness Act; support the extensions of the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) and Troubled Debt Restructuring (TDR) provisions from the CARES Act; support focused clarification of regulatory expectations re: ECOA and Reg B; support HUDs codifying court rulings for disparate impact; support extension of CARES Act provisions: Section 1102: Paycheck Protection Program, Section 4012: Community Bank Leverage Ratio, Section 4014: Current Expected Credit Loss (CECL), Section 4008: Deposit Insurance, Section 4013: Troubled Debt Restructuring (TDR), Section 4016: NCUAs Central Liquidity Facility (CLF), Section 1110: Economic Injury Disaster Loan (EIDL) Program; Conference Report for H.R. 6395, the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021; express concern re: The Senates version of the FY 2021 NDAA, S.4049; supports efforts to provide additional emergency funding for CDFIs; outlines several recommendations to improve the efficiency of NCUA budget; bipartisan beneficial ownership and BSA/AML reform legislation - the Corporate Transparency Act and the COUNTER Act; Notice of Ex Parte Presentations, Rules & Regulations Implementing the Tel. Consumer Prot. Act of 1991, CG Docket No. 02-278; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support $25 billion in rental assistance to the Treasury Department to allocate to state and local governments, as well as extends the eviction moratorium; support NCUA modernizing the agencys derivatives rule, changing from a prescriptive approach to a more flexible, principles-based approach; support appreciates the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance ; H.R. 133, the Consolidated Appropriations Act of 2021

Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act

Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; Overhead Transfer Rate (OTR) methodology and operating fee schedule; support of the FCC's efforts to establish and implement exemptions to the TCPAs consent requirement for important information about fraudulent activity, data breaches and available protections, and money transfers; supportive of the FCCs proposal to not limit the number of calls made under the exemption; Comment on Annual Certification and Data Collection Report Form (ACR) and the Certification Transaction Level Report (CTLR), concerned about the reporting burden and cybersecurity risks associated with the proposed ACR and CTRL; support the certainty and regulatory flexibility afforded by many of the new and updated Interagency Questions and Answers regarding flood insurance; express concern the proposed Community Development Financial Institutions Program application creates many such barriers, which ultimately will make it more difficult and unlikely that credit unions will obtain and maintain CDFI-designation; urge the Federal Housing Finance Agency (FHFA) to evaluate top credit union regulatory priorities, Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the National Credit Union Administration (NCUA) to evaluate the priority issues and enact the requested policy modifications re: Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the U.S. Department of the Treasury (Treasury) along with the Financial Crimes Enforcement Network (FinCEN) and the Internal Revenue Service (IRS) to evaluate the top credit union priorities; express concern with Section 2885 of S.4049, which would expand access to nominal leases on military installations for banks; support for Division F, the Corporate Transparency Act of 2019 and Division G, the COUNTER Act of 2019, of H.R.6395, which would make critical improvements to our Bank Secrecy Act (BSA)/anti-money laundering (AML)/beneficial ownership regime; support of a simplified loan forgiveness process for PPP loans under a $150,000 threshold, such as proposed in H.R.7777/S.4117, the Paycheck Protection Small Business Forgiveness Act; support a second round of PPP loans to the hardest hit small businesses; extend the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) that were enacted in section 4016 of the CARES Act and to extend the provisions from section 4013 of the CARES Act dealing with Troubled Debt Restructuring (TDR); support H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020; support excluding EIDL advances from the PPP forgiveness calculation, as proposed by bipartisan legislation in the House, HR.8361, the EIDL Forgiveness Act; supports legislation, H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020, which would provide temporary relief from the credit union member business lending (MBL) cap; support increase funding for the CDFI and CDRLF programs. Providing $1 billion in emergency funding for the CDFI Fund would allow more credit unions to access monies for specific programs; support the Health and Economic Recovery Omnibus Emergency Solutions Act (HEROES Act); support the inclusion of S.4159, the E-SIGN Modernization Act of 2020, in the relief package; credit unions, as not-for-profit cooperative institutions, should not be subject to the CECL standard; support a reduction in the level at which credit unions are considered well capitalized from a net-worth ratio of seven percent to six percent and adequately capitalized from six percent to five percent during the pandemic; reject any idea, even if well-meaning, that could place new hardships on credit unions; urges the Bureau of Consumer Financial Protection (Bureau or CFPB) to evaluate top credit union priorities, Delay Section 1071 Rulemaking, Electronic Disclosure Relief and Credit Card Accountability Responsibility and Disclosure Act of 2009 Act (CARD Act) Improvements, Temporarily Halt the Qualified Mortgage (QM) Rulemaking, Revise Home Mortgage Disclosure Act (HMDA) Rule and Reporting, Facilitate the London Interbank Offered Rate (LIBOR) Transition, Unfair, Deceptive, or Abusive Acts and Practices (UDAAP) Guidance and Rulemaking; urge NCUA provide relief to credit unions as they serve their members during the pandemic: Expanding Virtual Meetings, Managing Unexpected Share Growth, Additional Investment Opportunities, Capitalizing Interest on Loan Modifications, Adopting Broader Capital Reform, Finalizing an Efficient and Measured Budget; supports FinCEN defining an overall effective and reasonably designed AML program, including the explicit requirement for a risk-assessment; support automatic loan forgiveness for PPP loans under $150,000 and support any legislative efforts; support legislative efforts to amend the CARES Act to exclude Economic Injury Disaster Loans (EIDL) advance amounts from the calculation of loan forgiveness under the PPP; support initial 3508EZ form and the newly created 3508S form for loans under $50,000; support H.R. 8361, the EIDL Forgiveness Act; recommend a comment period of 90 days for all novel charter applications including the recent filings by Figure Bank for a national charter and Anchorage for a trust charter; TRACED Act; urged the Commission (FCC) not to impose additional restrictions on the existing exemption for informational calls placed to residential telephone numbers (Informational Calls Exemption); urges FinCEN to retain the current Recordkeeping and Travel Rule thresholds; supports the definition of money as proposed, which will resolve ambiguities surrounding applicability to convertible virtual currencies (CVCs); Thresholds for the Requirement to Collect, Retain, and Transmit Information Under the Recordkeeping and Travel Rules (Docket No.: FINCEN-2020-0002; RIN No.: 1506-AB41); Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support increase in size standards for North American Industry Classification System (NAICS) sectors related to finance and insurance, specifically NAICS code 522130 for credit unions; inclusion of S.4117, the Paycheck Protection Small Business Forgiveness Act; support the extensions of the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) and Troubled Debt Restructuring (TDR) provisions from the CARES Act; support focused clarification of regulatory expectations re: ECOA and Reg B; support HUDs codifying court rulings for disparate impact; support extension of CARES Act provisions: Section 1102: Paycheck Protection Program, Section 4012: Community Bank Leverage Ratio, Section 4014: Current Expected Credit Loss (CECL), Section 4008: Deposit Insurance, Section 4013: Troubled Debt Restructuring (TDR), Section 4016: NCUAs Central Liquidity Facility (CLF), Section 1110: Economic Injury Disaster Loan (EIDL) Program; Conference Report for H.R. 6395, the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021; express concern re: The Senates version of the FY 2021 NDAA, S.4049; supports efforts to provide additional emergency funding for CDFIs; outlines several recommendations to improve the efficiency of NCUA budget; bipartisan beneficial ownership and BSA/AML reform legislation - the Corporate Transparency Act and the COUNTER Act; Notice of Ex Parte Presentations, Rules & Regulations Implementing the Tel. Consumer Prot. Act of 1991, CG Docket No. 02-278; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support $25 billion in rental assistance to the Treasury Department to allocate to state and local governments, as well as extends the eviction moratorium; support NCUA modernizing the agencys derivatives rule, changing from a prescriptive approach to a more flexible, principles-based approach; support appreciates the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance ; H.R. 133, the Consolidated Appropriations Act of 2021

Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act

Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; Overhead Transfer Rate (OTR) methodology and operating fee schedule; support of the FCC's efforts to establish and implement exemptions to the TCPAs consent requirement for important information about fraudulent activity, data breaches and available protections, and money transfers; supportive of the FCCs proposal to not limit the number of calls made under the exemption; Comment on Annual Certification and Data Collection Report Form (ACR) and the Certification Transaction Level Report (CTLR), concerned about the reporting burden and cybersecurity risks associated with the proposed ACR and CTRL; support the certainty and regulatory flexibility afforded by many of the new and updated Interagency Questions and Answers regarding flood insurance; express concern the proposed Community Development Financial Institutions Program application creates many such barriers, which ultimately will make it more difficult and unlikely that credit unions will obtain and maintain CDFI-designation; urge the Federal Housing Finance Agency (FHFA) to evaluate top credit union regulatory priorities, Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the National Credit Union Administration (NCUA) to evaluate the priority issues and enact the requested policy modifications re: Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the U.S. Department of the Treasury (Treasury) along with the Financial Crimes Enforcement Network (FinCEN) and the Internal Revenue Service (IRS) to evaluate the top credit union priorities; express concern with Section 2885 of S.4049, which would expand access to nominal leases on military installations for banks; support for Division F, the Corporate Transparency Act of 2019 and Division G, the COUNTER Act of 2019, of H.R.6395, which would make critical improvements to our Bank Secrecy Act (BSA)/anti-money laundering (AML)/beneficial ownership regime; support of a simplified loan forgiveness process for PPP loans under a $150,000 threshold, such as proposed in H.R.7777/S.4117, the Paycheck Protection Small Business Forgiveness Act; support a second round of PPP loans to the hardest hit small businesses; extend the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) that were enacted in section 4016 of the CARES Act and to extend the provisions from section 4013 of the CARES Act dealing with Troubled Debt Restructuring (TDR); support H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020; support excluding EIDL advances from the PPP forgiveness calculation, as proposed by bipartisan legislation in the House, HR.8361, the EIDL Forgiveness Act; supports legislation, H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020, which would provide temporary relief from the credit union member business lending (MBL) cap; support increase funding for the CDFI and CDRLF programs. Providing $1 billion in emergency funding for the CDFI Fund would allow more credit unions to access monies for specific programs; support the Health and Economic Recovery Omnibus Emergency Solutions Act (HEROES Act); support the inclusion of S.4159, the E-SIGN Modernization Act of 2020, in the relief package; credit unions, as not-for-profit cooperative institutions, should not be subject to the CECL standard; support a reduction in the level at which credit unions are considered well capitalized from a net-worth ratio of seven percent to six percent and adequately capitalized from six percent to five percent during the pandemic; reject any idea, even if well-meaning, that could place new hardships on credit unions; urges the Bureau of Consumer Financial Protection (Bureau or CFPB) to evaluate top credit union priorities, Delay Section 1071 Rulemaking, Electronic Disclosure Relief and Credit Card Accountability Responsibility and Disclosure Act of 2009 Act (CARD Act) Improvements, Temporarily Halt the Qualified Mortgage (QM) Rulemaking, Revise Home Mortgage Disclosure Act (HMDA) Rule and Reporting, Facilitate the London Interbank Offered Rate (LIBOR) Transition, Unfair, Deceptive, or Abusive Acts and Practices (UDAAP) Guidance and Rulemaking; urge NCUA provide relief to credit unions as they serve their members during the pandemic: Expanding Virtual Meetings, Managing Unexpected Share Growth, Additional Investment Opportunities, Capitalizing Interest on Loan Modifications, Adopting Broader Capital Reform, Finalizing an Efficient and Measured Budget; supports FinCEN defining an overall effective and reasonably designed AML program, including the explicit requirement for a risk-assessment; support automatic loan forgiveness for PPP loans under $150,000 and support any legislative efforts; support legislative efforts to amend the CARES Act to exclude Economic Injury Disaster Loans (EIDL) advance amounts from the calculation of loan forgiveness under the PPP; support initial 3508EZ form and the newly created 3508S form for loans under $50,000; support H.R. 8361, the EIDL Forgiveness Act; recommend a comment period of 90 days for all novel charter applications including the recent filings by Figure Bank for a national charter and Anchorage for a trust charter; TRACED Act; urged the Commission (FCC) not to impose additional restrictions on the existing exemption for informational calls placed to residential telephone numbers (Informational Calls Exemption); urges FinCEN to retain the current Recordkeeping and Travel Rule thresholds; supports the definition of money as proposed, which will resolve ambiguities surrounding applicability to convertible virtual currencies (CVCs); Thresholds for the Requirement to Collect, Retain, and Transmit Information Under the Recordkeeping and Travel Rules (Docket No.: FINCEN-2020-0002; RIN No.: 1506-AB41); Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support increase in size standards for North American Industry Classification System (NAICS) sectors related to finance and insurance, specifically NAICS code 522130 for credit unions; inclusion of S.4117, the Paycheck Protection Small Business Forgiveness Act; support the extensions of the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) and Troubled Debt Restructuring (TDR) provisions from the CARES Act; support focused clarification of regulatory expectations re: ECOA and Reg B; support HUDs codifying court rulings for disparate impact; support extension of CARES Act provisions: Section 1102: Paycheck Protection Program, Section 4012: Community Bank Leverage Ratio, Section 4014: Current Expected Credit Loss (CECL), Section 4008: Deposit Insurance, Section 4013: Troubled Debt Restructuring (TDR), Section 4016: NCUAs Central Liquidity Facility (CLF), Section 1110: Economic Injury Disaster Loan (EIDL) Program; Conference Report for H.R. 6395, the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021; express concern re: The Senates version of the FY 2021 NDAA, S.4049; supports efforts to provide additional emergency funding for CDFIs; outlines several recommendations to improve the efficiency of NCUA budget; bipartisan beneficial ownership and BSA/AML reform legislation - the Corporate Transparency Act and the COUNTER Act; Notice of Ex Parte Presentations, Rules & Regulations Implementing the Tel. Consumer Prot. Act of 1991, CG Docket No. 02-278; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support $25 billion in rental assistance to the Treasury Department to allocate to state and local governments, as well as extends the eviction moratorium; support NCUA modernizing the agencys derivatives rule, changing from a prescriptive approach to a more flexible, principles-based approach; support appreciates the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance ; H.R. 133, the Consolidated Appropriations Act of 2021

Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act

Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; Overhead Transfer Rate (OTR) methodology and operating fee schedule; support of the FCC's efforts to establish and implement exemptions to the TCPAs consent requirement for important information about fraudulent activity, data breaches and available protections, and money transfers; supportive of the FCCs proposal to not limit the number of calls made under the exemption; Comment on Annual Certification and Data Collection Report Form (ACR) and the Certification Transaction Level Report (CTLR), concerned about the reporting burden and cybersecurity risks associated with the proposed ACR and CTRL; support the certainty and regulatory flexibility afforded by many of the new and updated Interagency Questions and Answers regarding flood insurance; express concern the proposed Community Development Financial Institutions Program application creates many such barriers, which ultimately will make it more difficult and unlikely that credit unions will obtain and maintain CDFI-designation; urge the Federal Housing Finance Agency (FHFA) to evaluate top credit union regulatory priorities, Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the National Credit Union Administration (NCUA) to evaluate the priority issues and enact the requested policy modifications re: Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the U.S. Department of the Treasury (Treasury) along with the Financial Crimes Enforcement Network (FinCEN) and the Internal Revenue Service (IRS) to evaluate the top credit union priorities; express concern with Section 2885 of S.4049, which would expand access to nominal leases on military installations for banks; support for Division F, the Corporate Transparency Act of 2019 and Division G, the COUNTER Act of 2019, of H.R.6395, which would make critical improvements to our Bank Secrecy Act (BSA)/anti-money laundering (AML)/beneficial ownership regime; support of a simplified loan forgiveness process for PPP loans under a $150,000 threshold, such as proposed in H.R.7777/S.4117, the Paycheck Protection Small Business Forgiveness Act; support a second round of PPP loans to the hardest hit small businesses; extend the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) that were enacted in section 4016 of the CARES Act and to extend the provisions from section 4013 of the CARES Act dealing with Troubled Debt Restructuring (TDR); support H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020; support excluding EIDL advances from the PPP forgiveness calculation, as proposed by bipartisan legislation in the House, HR.8361, the EIDL Forgiveness Act; supports legislation, H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020, which would provide temporary relief from the credit union member business lending (MBL) cap; support increase funding for the CDFI and CDRLF programs. Providing $1 billion in emergency funding for the CDFI Fund would allow more credit unions to access monies for specific programs; support the Health and Economic Recovery Omnibus Emergency Solutions Act (HEROES Act); support the inclusion of S.4159, the E-SIGN Modernization Act of 2020, in the relief package; credit unions, as not-for-profit cooperative institutions, should not be subject to the CECL standard; support a reduction in the level at which credit unions are considered well capitalized from a net-worth ratio of seven percent to six percent and adequately capitalized from six percent to five percent during the pandemic; reject any idea, even if well-meaning, that could place new hardships on credit unions; urges the Bureau of Consumer Financial Protection (Bureau or CFPB) to evaluate top credit union priorities, Delay Section 1071 Rulemaking, Electronic Disclosure Relief and Credit Card Accountability Responsibility and Disclosure Act of 2009 Act (CARD Act) Improvements, Temporarily Halt the Qualified Mortgage (QM) Rulemaking, Revise Home Mortgage Disclosure Act (HMDA) Rule and Reporting, Facilitate the London Interbank Offered Rate (LIBOR) Transition, Unfair, Deceptive, or Abusive Acts and Practices (UDAAP) Guidance and Rulemaking; urge NCUA provide relief to credit unions as they serve their members during the pandemic: Expanding Virtual Meetings, Managing Unexpected Share Growth, Additional Investment Opportunities, Capitalizing Interest on Loan Modifications, Adopting Broader Capital Reform, Finalizing an Efficient and Measured Budget; supports FinCEN defining an overall effective and reasonably designed AML program, including the explicit requirement for a risk-assessment; support automatic loan forgiveness for PPP loans under $150,000 and support any legislative efforts; support legislative efforts to amend the CARES Act to exclude Economic Injury Disaster Loans (EIDL) advance amounts from the calculation of loan forgiveness under the PPP; support initial 3508EZ form and the newly created 3508S form for loans under $50,000; support H.R. 8361, the EIDL Forgiveness Act; recommend a comment period of 90 days for all novel charter applications including the recent filings by Figure Bank for a national charter and Anchorage for a trust charter; TRACED Act; urged the Commission (FCC) not to impose additional restrictions on the existing exemption for informational calls placed to residential telephone numbers (Informational Calls Exemption); urges FinCEN to retain the current Recordkeeping and Travel Rule thresholds; supports the definition of money as proposed, which will resolve ambiguities surrounding applicability to convertible virtual currencies (CVCs); Thresholds for the Requirement to Collect, Retain, and Transmit Information Under the Recordkeeping and Travel Rules (Docket No.: FINCEN-2020-0002; RIN No.: 1506-AB41); Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support increase in size standards for North American Industry Classification System (NAICS) sectors related to finance and insurance, specifically NAICS code 522130 for credit unions; inclusion of S.4117, the Paycheck Protection Small Business Forgiveness Act; support the extensions of the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) and Troubled Debt Restructuring (TDR) provisions from the CARES Act; support focused clarification of regulatory expectations re: ECOA and Reg B; support HUDs codifying court rulings for disparate impact; support extension of CARES Act provisions: Section 1102: Paycheck Protection Program, Section 4012: Community Bank Leverage Ratio, Section 4014: Current Expected Credit Loss (CECL), Section 4008: Deposit Insurance, Section 4013: Troubled Debt Restructuring (TDR), Section 4016: NCUAs Central Liquidity Facility (CLF), Section 1110: Economic Injury Disaster Loan (EIDL) Program; Conference Report for H.R. 6395, the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021; express concern re: The Senates version of the FY 2021 NDAA, S.4049; supports efforts to provide additional emergency funding for CDFIs; outlines several recommendations to improve the efficiency of NCUA budget; bipartisan beneficial ownership and BSA/AML reform legislation - the Corporate Transparency Act and the COUNTER Act; Notice of Ex Parte Presentations, Rules & Regulations Implementing the Tel. Consumer Prot. Act of 1991, CG Docket No. 02-278; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support $25 billion in rental assistance to the Treasury Department to allocate to state and local governments, as well as extends the eviction moratorium; support NCUA modernizing the agencys derivatives rule, changing from a prescriptive approach to a more flexible, principles-based approach; support appreciates the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance ; H.R. 133, the Consolidated Appropriations Act of 2021

Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act