SARAH JACOBS

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions

Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions

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; 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; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions

Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions

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; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions

Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions

Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions

Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.

Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions

Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions

Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions

Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions

Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions

Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions

Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions

Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.

Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.

Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.

Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions

Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.

Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions

Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions