MAHLET MAKONNEN

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

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

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

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

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

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

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

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

Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.

Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.

Protect the credit union tax exemption; S. 151, the TRACED Act - modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill - reforms should require voice service providers to consult with call originators as they implement the STIR/SHAKEN call authentication framework - require FCC to promulgate rules for the safe harbor available to voice service providers that establish a process to give notice to legitimate callers prior to their calls being blocked and, subsequently, correct any unintended blocking; establish a broad definition of automatic telephone dialing system or autodialer under the TCPA that only includes equipment that uses a random or sequential number generator to store or produce numbers and dial those numbers without human intervention - conduct reforms to help credit unions contact their members with important account information - permit callers to establish a reasonable opt-out method for revoking their consent to be contacted - remove language that goes beyond the scope of addressing the illegal actors who make abusive automated calls and in essence harms businesses and consumers by impeding legitimate calls that consumers actually need or want, HR 946 - support creating reassigned numbers database using existing numbering databases, (CG Docket No. 17-59) - provide a comprehensive safe harbor from TCPA liability for callers who use the database regularly but make a call to a reassigned number due to database errors - urge FCC to seek public comment on draft Declaratory Ruling, Advanced Methods to Target and Eliminate Unlawful Robocalls, (CG Docket No. 17-59, WC Docket No. 17-97); financial literacy - Support HR 275 and the goals and ideals of financial literacy month; Department of Defense - oppose an amendment to provide banks with rent-free leases on military bases under the John S. McCain National Defense Authorization Act - exempt loans to veteran-owned businesses from the credit union member business lending cap, HR 2305; Postal Banking - the United States Postal Service should not provide banking services which will be beyond its core competencies, will raise a number of serious regulatory and consumer protection questions, and will present significant competitive issues for private sector entities; Banking regulation and supervision - support the use of formal rulemaking versus informal guidance - agencies should clarify how guidance is treated, as inconsistencies can lead to compliance confusion; ensure that examiners treat regulations and guidance consistently - improve the examination process for financial institutions by passing the Financial Institutions Examination Fairness and Reform Act; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time; Supervisory Committee Audits and Verifications (RIN 3133-AE91) - NCUA should remove the report on examination of internal controls over call reporting alternative audit option - remove the 120-day language in engagement letters to outside, compensated auditors regarding the required written report - support Appendix A to Part 715 alternative audit option - do not include other areas of review in Appendix A - retain Supervisory Committee Guide; Request for Information Regarding Consumer Credit Card Market (Docket No. CFPB-2019-0002) - encourage effective credit card disclosure use, including flexibility to provide required disclosures via mobile banking platforms - support providing fair and transparent credit products and services - support changes to regulations carrying out the Credit Card Accountability Responsibility and Disclosure Act of 2009 as the consumer credit card market evolves - support reporting on the credit card market to ensure practices align with CARD Act - support effective, simple and user friendly credit card disclosures - support allocating resources from Office of Cost-Benefit Analysis toward innovation; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; oppose the Green Amendment (#29) to H.R. 1500 which would reinstate the CFPBs rule on arbitration agreements which Congress voted to disapprove in 2017; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; Property Assessed Clean Energy Loans - support imposing ability-to-repay underwriting requirements for PACE loans - support imposing civil liability on violators of the ATR requirements under section 130 of the Truth In Lending Act - support adopting Truth In Lending - RESPA disclosures for PACE loans; Payday, Vehicle Title, and Certain High-Cost Installment Loans (RIN 3170-AA80) - support rescission of mandatory ability-to-repay (ATR) underwriting requirements - support for delay of compliance date, RIN3170-AA95 - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan (PAL) programs for credit unions - recommend expanding the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales and Computer Employees, (RIN 1235-AA20) - supports the Department of Labors (DOL) proposed adjustments to overtime exemption rules under the Fair Labor Standards Act (FLSA) - urge DOL to consider additional options and guidance to reduce burdens for smaller credit unions - support regulatory flexibility for certain bonuses, incentive payments, and commissions - urge DOL to commit to a future formal assessment of the four-year review of the salary levels, in lieu of automatic reviews or increases; Ginnie Mae, Request for Input on Pooling Eligibility Changes - recommend that Ginnie Mae first allow the VA to complete its own evaluation of VA cash-out refinances, then closely evaluate other changes before removing cash out refinance loans made through the U.S. Department of Veterans Affairs from the Ginnie Mae II Multi-Issuer Program (GIIMIP) - Before excluding VA cash-out refinances, Ginnie Mae should complete further review to determine whether there is more than a correlation between the propensity to rapidly prepay VA loans and the different LTV requirements in the VA program compared to those of the Federal Housing Administration (FHA), Fannie Mae, and Freddie Mac - support a de minimis standard restricting inclusion of cash-out refinances for VA loans in the GII MIP; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws (RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; supports a strong independent NCUA; Consideration of the Financial Services and General Government Appropriations Bill - supports the language in the draft bill to keep funding for the NCUA's Community Development Revolving Loan Fund (CDRLF) at a level of $2 million and to fund the Community Development Financial Institutions (CDFI) Fund at a level of $300 million; NCUA should maintain the current regulation requiring annual review by a federal credit union (FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; A Review of the Appraisal Industry - a formal appraisal should not be required for commercial real estate appraisals; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; support amendment to the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act (COUNTER Act), HR 2514; support amendment to the Corporate Transparency Act of 2019, HR 2513; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support reform bill addressing beneficial ownership requirements; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans (RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases; support the SBAs modernizing the requirements for Certified Development Companies who provide vital 504 program loans; support Title IV of H.R. 3300, the Economic Mobility Act of 2019, which would repeal the 21 percent excise tax imposed on certain not-for-profits for providing certain fringe benefits under the Tax Cuts and Jobs Act (TCJA).; support 2019 NCUA Regulatory Review of 1/3 of NCUA regualtions;

Protect the credit union tax exemption; S. 151, the TRACED Act - modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill - reforms should require voice service providers to consult with call originators as they implement the STIR/SHAKEN call authentication framework - require FCC to promulgate rules for the safe harbor available to voice service providers that establish a process to give notice to legitimate callers prior to their calls being blocked and, subsequently, correct any unintended blocking; establish a broad definition of automatic telephone dialing system or autodialer under the TCPA that only includes equipment that uses a random or sequential number generator to store or produce numbers and dial those numbers without human intervention - conduct reforms to help credit unions contact their members with important account information - permit callers to establish a reasonable opt-out method for revoking their consent to be contacted - remove language that goes beyond the scope of addressing the illegal actors who make abusive automated calls and in essence harms businesses and consumers by impeding legitimate calls that consumers actually need or want, HR 946 - support creating reassigned numbers database using existing numbering databases, (CG Docket No. 17-59) - provide a comprehensive safe harbor from TCPA liability for callers who use the database regularly but make a call to a reassigned number due to database errors - urge FCC to seek public comment on draft Declaratory Ruling, Advanced Methods to Target and Eliminate Unlawful Robocalls, (CG Docket No. 17-59, WC Docket No. 17-97); financial literacy - Support HR 275 and the goals and ideals of financial literacy month; Department of Defense - oppose an amendment to provide banks with rent-free leases on military bases under the John S. McCain National Defense Authorization Act - exempt loans to veteran-owned businesses from the credit union member business lending cap, HR 2305; Postal Banking - the United States Postal Service should not provide banking services which will be beyond its core competencies, will raise a number of serious regulatory and consumer protection questions, and will present significant competitive issues for private sector entities; Banking regulation and supervision - support the use of formal rulemaking versus informal guidance - agencies should clarify how guidance is treated, as inconsistencies can lead to compliance confusion; ensure that examiners treat regulations and guidance consistently - improve the examination process for financial institutions by passing the Financial Institutions Examination Fairness and Reform Act; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time; Supervisory Committee Audits and Verifications (RIN 3133-AE91) - NCUA should remove the report on examination of internal controls over call reporting alternative audit option - remove the 120-day language in engagement letters to outside, compensated auditors regarding the required written report - support Appendix A to Part 715 alternative audit option - do not include other areas of review in Appendix A - retain Supervisory Committee Guide; Request for Information Regarding Consumer Credit Card Market (Docket No. CFPB-2019-0002) - encourage effective credit card disclosure use, including flexibility to provide required disclosures via mobile banking platforms - support providing fair and transparent credit products and services - support changes to regulations carrying out the Credit Card Accountability Responsibility and Disclosure Act of 2009 as the consumer credit card market evolves - support reporting on the credit card market to ensure practices align with CARD Act - support effective, simple and user friendly credit card disclosures - support allocating resources from Office of Cost-Benefit Analysis toward innovation; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; oppose the Green Amendment (#29) to H.R. 1500 which would reinstate the CFPBs rule on arbitration agreements which Congress voted to disapprove in 2017; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; Property Assessed Clean Energy Loans - support imposing ability-to-repay underwriting requirements for PACE loans - support imposing civil liability on violators of the ATR requirements under section 130 of the Truth In Lending Act - support adopting Truth In Lending - RESPA disclosures for PACE loans; Payday, Vehicle Title, and Certain High-Cost Installment Loans (RIN 3170-AA80) - support rescission of mandatory ability-to-repay (ATR) underwriting requirements - support for delay of compliance date, RIN3170-AA95 - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan (PAL) programs for credit unions - recommend expanding the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales and Computer Employees, (RIN 1235-AA20) - supports the Department of Labors (DOL) proposed adjustments to overtime exemption rules under the Fair Labor Standards Act (FLSA) - urge DOL to consider additional options and guidance to reduce burdens for smaller credit unions - support regulatory flexibility for certain bonuses, incentive payments, and commissions - urge DOL to commit to a future formal assessment of the four-year review of the salary levels, in lieu of automatic reviews or increases; Ginnie Mae, Request for Input on Pooling Eligibility Changes - recommend that Ginnie Mae first allow the VA to complete its own evaluation of VA cash-out refinances, then closely evaluate other changes before removing cash out refinance loans made through the U.S. Department of Veterans Affairs from the Ginnie Mae II Multi-Issuer Program (GIIMIP) - Before excluding VA cash-out refinances, Ginnie Mae should complete further review to determine whether there is more than a correlation between the propensity to rapidly prepay VA loans and the different LTV requirements in the VA program compared to those of the Federal Housing Administration (FHA), Fannie Mae, and Freddie Mac - support a de minimis standard restricting inclusion of cash-out refinances for VA loans in the GII MIP; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws (RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; supports a strong independent NCUA; Consideration of the Financial Services and General Government Appropriations Bill - supports the language in the draft bill to keep funding for the NCUA's Community Development Revolving Loan Fund (CDRLF) at a level of $2 million and to fund the Community Development Financial Institutions (CDFI) Fund at a level of $300 million; NCUA should maintain the current regulation requiring annual review by a federal credit union (FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; A Review of the Appraisal Industry - a formal appraisal should not be required for commercial real estate appraisals; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; support amendment to the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act (COUNTER Act), HR 2514; support amendment to the Corporate Transparency Act of 2019, HR 2513; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support reform bill addressing beneficial ownership requirements; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans (RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases; support the SBAs modernizing the requirements for Certified Development Companies who provide vital 504 program loans; support Title IV of H.R. 3300, the Economic Mobility Act of 2019, which would repeal the 21 percent excise tax imposed on certain not-for-profits for providing certain fringe benefits under the Tax Cuts and Jobs Act (TCJA).; support 2019 NCUA Regulatory Review of 1/3 of NCUA regulations.

Protect the credit union tax exemption; S. 151, the TRACED Act - modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill - reforms should require voice service providers to consult with call originators as they implement the STIR/SHAKEN call authentication framework - require FCC to promulgate rules for the safe harbor available to voice service providers that establish a process to give notice to legitimate callers prior to their calls being blocked and, subsequently, correct any unintended blocking; establish a broad definition of automatic telephone dialing system or autodialer under the TCPA that only includes equipment that uses a random or sequential number generator to store or produce numbers and dial those numbers without human intervention - conduct reforms to help credit unions contact their members with important account information - permit callers to establish a reasonable opt-out method for revoking their consent to be contacted - remove language that goes beyond the scope of addressing the illegal actors who make abusive automated calls and in essence harms businesses and consumers by impeding legitimate calls that consumers actually need or want, HR 946 - support creating reassigned numbers database using existing numbering databases, (CG Docket No. 17-59) - provide a comprehensive safe harbor from TCPA liability for callers who use the database regularly but make a call to a reassigned number due to database errors - urge FCC to seek public comment on draft Declaratory Ruling, Advanced Methods to Target and Eliminate Unlawful Robocalls, (CG Docket No. 17-59, WC Docket No. 17-97); financial literacy - Support HR 275 and the goals and ideals of financial literacy month; Department of Defense - oppose an amendment to provide banks with rent-free leases on military bases under the John S. McCain National Defense Authorization Act - exempt loans to veteran-owned businesses from the credit union member business lending cap, HR 2305; Postal Banking - the United States Postal Service should not provide banking services which will be beyond its core competencies, will raise a number of serious regulatory and consumer protection questions, and will present significant competitive issues for private sector entities; Banking regulation and supervision - support the use of formal rulemaking versus informal guidance - agencies should clarify how guidance is treated, as inconsistencies can lead to compliance confusion; ensure that examiners treat regulations and guidance consistently - improve the examination process for financial institutions by passing the Financial Institutions Examination Fairness and Reform Act; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time; Supervisory Committee Audits and Verifications (RIN 3133-AE91) - NCUA should remove the report on examination of internal controls over call reporting alternative audit option - remove the 120-day language in engagement letters to outside, compensated auditors regarding the required written report - support Appendix A to Part 715 alternative audit option - do not include other areas of review in Appendix A - retain Supervisory Committee Guide; Request for Information Regarding Consumer Credit Card Market (Docket No. CFPB-2019-0002) - encourage effective credit card disclosure use, including flexibility to provide required disclosures via mobile banking platforms - support providing fair and transparent credit products and services - support changes to regulations carrying out the Credit Card Accountability Responsibility and Disclosure Act of 2009 as the consumer credit card market evolves - support reporting on the credit card market to ensure practices align with CARD Act - support effective, simple and user friendly credit card disclosures - support allocating resources from Office of Cost-Benefit Analysis toward innovation; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; oppose the Green Amendment (#29) to H.R. 1500 which would reinstate the CFPBs rule on arbitration agreements which Congress voted to disapprove in 2017; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; Property Assessed Clean Energy Loans - support imposing ability-to-repay underwriting requirements for PACE loans - support imposing civil liability on violators of the ATR requirements under section 130 of the Truth In Lending Act - support adopting Truth In Lending - RESPA disclosures for PACE loans; Payday, Vehicle Title, and Certain High-Cost Installment Loans (RIN 3170-AA80) - support rescission of mandatory ability-to-repay (ATR) underwriting requirements - support for delay of compliance date, RIN3170-AA95 - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan (PAL) programs for credit unions - recommend expanding the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales and Computer Employees, (RIN 1235-AA20) - supports the Department of Labors (DOL) proposed adjustments to overtime exemption rules under the Fair Labor Standards Act (FLSA) - urge DOL to consider additional options and guidance to reduce burdens for smaller credit unions - support regulatory flexibility for certain bonuses, incentive payments, and commissions - urge DOL to commit to a future formal assessment of the four-year review of the salary levels, in lieu of automatic reviews or increases; Ginnie Mae, Request for Input on Pooling Eligibility Changes - recommend that Ginnie Mae first allow the VA to complete its own evaluation of VA cash-out refinances, then closely evaluate other changes before removing cash out refinance loans made through the U.S. Department of Veterans Affairs from the Ginnie Mae II Multi-Issuer Program (GIIMIP) - Before excluding VA cash-out refinances, Ginnie Mae should complete further review to determine whether there is more than a correlation between the propensity to rapidly prepay VA loans and the different LTV requirements in the VA program compared to those of the Federal Housing Administration (FHA), Fannie Mae, and Freddie Mac - support a de minimis standard restricting inclusion of cash-out refinances for VA loans in the GII MIP; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws (RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; supports a strong independent NCUA; Consideration of the Financial Services and General Government Appropriations Bill - supports the language in the draft bill to keep funding for the NCUA's Community Development Revolving Loan Fund (CDRLF) at a level of $2 million and to fund the Community Development Financial Institutions (CDFI) Fund at a level of $300 million; NCUA should maintain the current regulation requiring annual review by a federal credit union (FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; A Review of the Appraisal Industry - a formal appraisal should not be required for commercial real estate appraisals; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; support amendment to the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act (COUNTER Act), HR 2514; support amendment to the Corporate Transparency Act of 2019, HR 2513; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support reform bill addressing beneficial ownership requirements; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans (RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases; support the SBAs modernizing the requirements for Certified Development Companies who provide vital 504 program loans; support Title IV of H.R. 3300, the Economic Mobility Act of 2019, which would repeal the 21 percent excise tax imposed on certain not-for-profits for providing certain fringe benefits under the Tax Cuts and Jobs Act (TCJA).; support 2019 NCUA Regulatory Review of 1/3 of NCUA regualtions;

Protect the credit union tax exemption; S. 151, the TRACED Act - modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill - reforms should require voice service providers to consult with call originators as they implement the STIR/SHAKEN call authentication framework - require FCC to promulgate rules for the safe harbor available to voice service providers that establish a process to give notice to legitimate callers prior to their calls being blocked and, subsequently, correct any unintended blocking; establish a broad definition of automatic telephone dialing system or autodialer under the TCPA that only includes equipment that uses a random or sequential number generator to store or produce numbers and dial those numbers without human intervention - conduct reforms to help credit unions contact their members with important account information - permit callers to establish a reasonable opt-out method for revoking their consent to be contacted - remove language that goes beyond the scope of addressing the illegal actors who make abusive automated calls and in essence harms businesses and consumers by impeding legitimate calls that consumers actually need or want, HR 946 - support creating reassigned numbers database using existing numbering databases, (CG Docket No. 17-59) - provide a comprehensive safe harbor from TCPA liability for callers who use the database regularly but make a call to a reassigned number due to database errors - urge FCC to seek public comment on draft Declaratory Ruling, Advanced Methods to Target and Eliminate Unlawful Robocalls, (CG Docket No. 17-59, WC Docket No. 17-97); financial literacy - Support HR 275 and the goals and ideals of financial literacy month; Department of Defense - oppose an amendment to provide banks with rent-free leases on military bases under the John S. McCain National Defense Authorization Act - exempt loans to veteran-owned businesses from the credit union member business lending cap, HR 2305; Postal Banking - the United States Postal Service should not provide banking services which will be beyond its core competencies, will raise a number of serious regulatory and consumer protection questions, and will present significant competitive issues for private sector entities; Banking regulation and supervision - support the use of formal rulemaking versus informal guidance - agencies should clarify how guidance is treated, as inconsistencies can lead to compliance confusion; ensure that examiners treat regulations and guidance consistently - improve the examination process for financial institutions by passing the Financial Institutions Examination Fairness and Reform Act; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time; Supervisory Committee Audits and Verifications (RIN 3133-AE91) - NCUA should remove the report on examination of internal controls over call reporting alternative audit option - remove the 120-day language in engagement letters to outside, compensated auditors regarding the required written report - support Appendix A to Part 715 alternative audit option - do not include other areas of review in Appendix A - retain Supervisory Committee Guide; Request for Information Regarding Consumer Credit Card Market (Docket No. CFPB-2019-0002) - encourage effective credit card disclosure use, including flexibility to provide required disclosures via mobile banking platforms - support providing fair and transparent credit products and services - support changes to regulations carrying out the Credit Card Accountability Responsibility and Disclosure Act of 2009 as the consumer credit card market evolves - support reporting on the credit card market to ensure practices align with CARD Act - support effective, simple and user friendly credit card disclosures - support allocating resources from Office of Cost-Benefit Analysis toward innovation; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; oppose the Green Amendment (#29) to H.R. 1500 which would reinstate the CFPBs rule on arbitration agreements which Congress voted to disapprove in 2017; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; Property Assessed Clean Energy Loans - support imposing ability-to-repay underwriting requirements for PACE loans - support imposing civil liability on violators of the ATR requirements under section 130 of the Truth In Lending Act - support adopting Truth In Lending - RESPA disclosures for PACE loans; Payday, Vehicle Title, and Certain High-Cost Installment Loans (RIN 3170-AA80) - support rescission of mandatory ability-to-repay (ATR) underwriting requirements - support for delay of compliance date, RIN3170-AA95 - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan (PAL) programs for credit unions - recommend expanding the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales and Computer Employees, (RIN 1235-AA20) - supports the Department of Labors (DOL) proposed adjustments to overtime exemption rules under the Fair Labor Standards Act (FLSA) - urge DOL to consider additional options and guidance to reduce burdens for smaller credit unions - support regulatory flexibility for certain bonuses, incentive payments, and commissions - urge DOL to commit to a future formal assessment of the four-year review of the salary levels, in lieu of automatic reviews or increases; Ginnie Mae, Request for Input on Pooling Eligibility Changes - recommend that Ginnie Mae first allow the VA to complete its own evaluation of VA cash-out refinances, then closely evaluate other changes before removing cash out refinance loans made through the U.S. Department of Veterans Affairs from the Ginnie Mae II Multi-Issuer Program (GIIMIP) - Before excluding VA cash-out refinances, Ginnie Mae should complete further review to determine whether there is more than a correlation between the propensity to rapidly prepay VA loans and the different LTV requirements in the VA program compared to those of the Federal Housing Administration (FHA), Fannie Mae, and Freddie Mac - support a de minimis standard restricting inclusion of cash-out refinances for VA loans in the GII MIP; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws (RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; supports a strong independent NCUA; Consideration of the Financial Services and General Government Appropriations Bill - supports the language in the draft bill to keep funding for the NCUA's Community Development Revolving Loan Fund (CDRLF) at a level of $2 million and to fund the Community Development Financial Institutions (CDFI) Fund at a level of $300 million; NCUA should maintain the current regulation requiring annual review by a federal credit union (FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; A Review of the Appraisal Industry - a formal appraisal should not be required for commercial real estate appraisals; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; support amendment to the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act (COUNTER Act), HR 2514; support amendment to the Corporate Transparency Act of 2019, HR 2513; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support reform bill addressing beneficial ownership requirements; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans (RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases; support the SBAs modernizing the requirements for Certified Development Companies who provide vital 504 program loans; support Title IV of H.R. 3300, the Economic Mobility Act of 2019, which would repeal the 21 percent excise tax imposed on certain not-for-profits for providing certain fringe benefits under the Tax Cuts and Jobs Act (TCJA).; support 2019 NCUA Regulatory Review of 1/3 of NCUA regulations.

Protect the credit union tax exemption; S. 151, the TRACED Act - modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill - reforms should require voice service providers to consult with call originators as they implement the STIR/SHAKEN call authentication framework - require FCC to promulgate rules for the safe harbor available to voice service providers that establish a process to give notice to legitimate callers prior to their calls being blocked and, subsequently, correct any unintended blocking; establish a broad definition of automatic telephone dialing system or autodialer under the TCPA that only includes equipment that uses a random or sequential number generator to store or produce numbers and dial those numbers without human intervention - conduct reforms to help credit unions contact their members with important account information - permit callers to establish a reasonable opt-out method for revoking their consent to be contacted - remove language that goes beyond the scope of addressing the illegal actors who make abusive automated calls and in essence harms businesses and consumers by impeding legitimate calls that consumers actually need or want, HR 946 - support creating reassigned numbers database using existing numbering databases, (CG Docket No. 17-59) - provide a comprehensive safe harbor from TCPA liability for callers who use the database regularly but make a call to a reassigned number due to database errors - urge FCC to seek public comment on draft Declaratory Ruling, Advanced Methods to Target and Eliminate Unlawful Robocalls, (CG Docket No. 17-59, WC Docket No. 17-97); financial literacy - Support HR 275 and the goals and ideals of financial literacy month; Department of Defense - oppose an amendment to provide banks with rent-free leases on military bases under the John S. McCain National Defense Authorization Act - exempt loans to veteran-owned businesses from the credit union member business lending cap, HR 2305; Postal Banking - the United States Postal Service should not provide banking services which will be beyond its core competencies, will raise a number of serious regulatory and consumer protection questions, and will present significant competitive issues for private sector entities; Banking regulation and supervision - support the use of formal rulemaking versus informal guidance - agencies should clarify how guidance is treated, as inconsistencies can lead to compliance confusion; ensure that examiners treat regulations and guidance consistently - improve the examination process for financial institutions by passing the Financial Institutions Examination Fairness and Reform Act; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time; Supervisory Committee Audits and Verifications (RIN 3133-AE91) - NCUA should remove the report on examination of internal controls over call reporting alternative audit option - remove the 120-day language in engagement letters to outside, compensated auditors regarding the required written report - support Appendix A to Part 715 alternative audit option - do not include other areas of review in Appendix A - retain Supervisory Committee Guide; Request for Information Regarding Consumer Credit Card Market (Docket No. CFPB-2019-0002) - encourage effective credit card disclosure use, including flexibility to provide required disclosures via mobile banking platforms - support providing fair and transparent credit products and services - support changes to regulations carrying out the Credit Card Accountability Responsibility and Disclosure Act of 2009 as the consumer credit card market evolves - support reporting on the credit card market to ensure practices align with CARD Act - support effective, simple and user friendly credit card disclosures - support allocating resources from Office of Cost-Benefit Analysis toward innovation; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; oppose the Green Amendment (#29) to H.R. 1500 which would reinstate the CFPBs rule on arbitration agreements which Congress voted to disapprove in 2017; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; Property Assessed Clean Energy Loans - support imposing ability-to-repay underwriting requirements for PACE loans - support imposing civil liability on violators of the ATR requirements under section 130 of the Truth In Lending Act - support adopting Truth In Lending - RESPA disclosures for PACE loans; Payday, Vehicle Title, and Certain High-Cost Installment Loans (RIN 3170-AA80) - support rescission of mandatory ability-to-repay (ATR) underwriting requirements - support for delay of compliance date, RIN3170-AA95 - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan (PAL) programs for credit unions - recommend expanding the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales and Computer Employees, (RIN 1235-AA20) - supports the Department of Labors (DOL) proposed adjustments to overtime exemption rules under the Fair Labor Standards Act (FLSA) - urge DOL to consider additional options and guidance to reduce burdens for smaller credit unions - support regulatory flexibility for certain bonuses, incentive payments, and commissions - urge DOL to commit to a future formal assessment of the four-year review of the salary levels, in lieu of automatic reviews or increases; Ginnie Mae, Request for Input on Pooling Eligibility Changes - recommend that Ginnie Mae first allow the VA to complete its own evaluation of VA cash-out refinances, then closely evaluate other changes before removing cash out refinance loans made through the U.S. Department of Veterans Affairs from the Ginnie Mae II Multi-Issuer Program (GIIMIP) - Before excluding VA cash-out refinances, Ginnie Mae should complete further review to determine whether there is more than a correlation between the propensity to rapidly prepay VA loans and the different LTV requirements in the VA program compared to those of the Federal Housing Administration (FHA), Fannie Mae, and Freddie Mac - support a de minimis standard restricting inclusion of cash-out refinances for VA loans in the GII MIP; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws (RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; supports a strong independent NCUA; Consideration of the Financial Services and General Government Appropriations Bill - supports the language in the draft bill to keep funding for the NCUA's Community Development Revolving Loan Fund (CDRLF) at a level of $2 million and to fund the Community Development Financial Institutions (CDFI) Fund at a level of $300 million; NCUA should maintain the current regulation requiring annual review by a federal credit union (FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; A Review of the Appraisal Industry - a formal appraisal should not be required for commercial real estate appraisals; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; support amendment to the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act (COUNTER Act), HR 2514; support amendment to the Corporate Transparency Act of 2019, HR 2513; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support reform bill addressing beneficial ownership requirements; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans (RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases; support the SBAs modernizing the requirements for Certified Development Companies who provide vital 504 program loans; support Title IV of H.R. 3300, the Economic Mobility Act of 2019, which would repeal the 21 percent excise tax imposed on certain not-for-profits for providing certain fringe benefits under the Tax Cuts and Jobs Act (TCJA).; support 2019 NCUA Regulatory Review of 1/3 of NCUA regulations.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support legislation such as H.R. 4067, the Financial Inclusion in Banking Act of 2019, which would direct the CFPBs Office of Community Affairs to research how to increase financial inclusion for underserved communities; supports CFPB Director Kathy Kraningers efforts to provide financial institutions with regulatory certainty and targeted relief, while focusing the CFPBs efforts on bad actors; support increased focus on diversity, equity, and inclusion (DEI) within the American economy and the industry; support laws and regulations aimed at detecting and preventing discrimination, as well as the legal mechanisms used to protect fundamental consumer interests; support HUDs objective of updating the Disparate Impact Rule by aligning it more closely with the Supreme Courts decision in Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc., (Inclusive Communities); support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support H.R. 2513, the Corporate Transparency Act of 2019 and the COUNTER Act of 2019; support efforts to modernize the Currency Transaction Report (CTR) threshold by indexing it for inflation; support The Business of Insurance Regulatory Reform Act of 2019; support tech sprints; support regulatory efforts to modernize and streamline supervisory processes; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; Support Interbank real-time gross settlement of faster payments docket No. OP-1670; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; advocate against an expanded consumer compliance examination program; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support implementing regulations that clarify that the requirements of the CCPA and its implementing regulations do not apply to organizations that solely collect GLBA-covered information; support a delay in enforcement of the CCPA; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; H.R. 5315, the Expanding Opportunity for MDIs Act, offered by Representative Joyce Beatty (D-OH) and H.R. 5322, the Ensuring Diversity in Community Banking Act of 2019; support keeping legislative reform of the housing finance system as a priority for the Senate Committee on Banking, Housing Committee on Banking, Housing & Urban Affairs and the House Committee on Financial Services; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; support S. 2563, the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings Act (ILLICIT CASH Act).

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support legislation such as H.R. 4067, the Financial Inclusion in Banking Act of 2019, which would direct the CFPBs Office of Community Affairs to research how to increase financial inclusion for underserved communities; supports CFPB Director Kathy Kraningers efforts to provide financial institutions with regulatory certainty and targeted relief, while focusing the CFPBs efforts on bad actors; support increased focus on diversity, equity, and inclusion (DEI) within the American economy and the industry; support laws and regulations aimed at detecting and preventing discrimination, as well as the legal mechanisms used to protect fundamental consumer interests; support HUDs objective of updating the Disparate Impact Rule by aligning it more closely with the Supreme Courts decision in Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc., (Inclusive Communities); support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support H.R. 2513, the Corporate Transparency Act of 2019 and the COUNTER Act of 2019; support efforts to modernize the Currency Transaction Report (CTR) threshold by indexing it for inflation; support The Business of Insurance Regulatory Reform Act of 2019; support tech sprints; support regulatory efforts to modernize and streamline supervisory processes; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; Support Interbank real-time gross settlement of faster payments docket No. OP-1670; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; advocate against an expanded consumer compliance examination program; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support implementing regulations that clarify that the requirements of the CCPA and its implementing regulations do not apply to organizations that solely collect GLBA-covered information; support a delay in enforcement of the CCPA; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; H.R. 5315, the Expanding Opportunity for MDIs Act, offered by Representative Joyce Beatty (D-OH) and H.R. 5322, the Ensuring Diversity in Community Banking Act of 2019; support keeping legislative reform of the housing finance system as a priority for the Senate Committee on Banking, Housing Committee on Banking, Housing & Urban Affairs and the House Committee on Financial Services; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; support S. 2563, the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings Act (ILLICIT CASH Act).

Protect the credit union tax exemption; S. 151, the TRACED Act - modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill - reforms should require voice service providers to consult with call originators as they implement the STIR/SHAKEN call authentication framework - require FCC to promulgate rules for the safe harbor available to voice service providers that establish a process to give notice to legitimate callers prior to their calls being blocked and, subsequently, correct any unintended blocking; establish a broad definition of automatic telephone dialing system or autodialer under the TCPA that only includes equipment that uses a random or sequential number generator to store or produce numbers and dial those numbers without human intervention - conduct reforms to help credit unions contact their members with important account information - permit callers to establish a reasonable opt-out method for revoking their consent to be contacted - remove language that goes beyond the scope of addressing the illegal actors who make abusive automated calls and in essence harms businesses and consumers by impeding legitimate calls that consumers actually need or want, HR 946 - support creating reassigned numbers database using existing numbering databases, (CG Docket No. 17-59) - provide a comprehensive safe harbor from TCPA liability for callers who use the database regularly but make a call to a reassigned number due to database errors - urge FCC to seek public comment on draft Declaratory Ruling, Advanced Methods to Target and Eliminate Unlawful Robocalls, (CG Docket No. 17-59, WC Docket No. 17-97); financial literacy - Support HR 275 and the goals and ideals of financial literacy month; Department of Defense - oppose an amendment to provide banks with rent-free leases on military bases under the John S. McCain National Defense Authorization Act - exempt loans to veteran-owned businesses from the credit union member business lending cap, HR 2305; Postal Banking - the United States Postal Service should not provide banking services which will be beyond its core competencies, will raise a number of serious regulatory and consumer protection questions, and will present significant competitive issues for private sector entities; Banking regulation and supervision - support the use of formal rulemaking versus informal guidance - agencies should clarify how guidance is treated, as inconsistencies can lead to compliance confusion; ensure that examiners treat regulations and guidance consistently - improve the examination process for financial institutions by passing the Financial Institutions Examination Fairness and Reform Act; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time; Supervisory Committee Audits and Verifications (RIN 3133-AE91) - NCUA should remove the report on examination of internal controls over call reporting alternative audit option - remove the 120-day language in engagement letters to outside, compensated auditors regarding the required written report - support Appendix A to Part 715 alternative audit option - do not include other areas of review in Appendix A - retain Supervisory Committee Guide; Request for Information Regarding Consumer Credit Card Market (Docket No. CFPB-2019-0002) - encourage effective credit card disclosure use, including flexibility to provide required disclosures via mobile banking platforms - support providing fair and transparent credit products and services - support changes to regulations carrying out the Credit Card Accountability Responsibility and Disclosure Act of 2009 as the consumer credit card market evolves - support reporting on the credit card market to ensure practices align with CARD Act - support effective, simple and user friendly credit card disclosures - support allocating resources from Office of Cost-Benefit Analysis toward innovation; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; oppose the Green Amendment (#29) to H.R. 1500 which would reinstate the CFPBs rule on arbitration agreements which Congress voted to disapprove in 2017; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; Property Assessed Clean Energy Loans - support imposing ability-to-repay underwriting requirements for PACE loans - support imposing civil liability on violators of the ATR requirements under section 130 of the Truth In Lending Act - support adopting Truth In Lending - RESPA disclosures for PACE loans; Payday, Vehicle Title, and Certain High-Cost Installment Loans (RIN 3170-AA80) - support rescission of mandatory ability-to-repay (ATR) underwriting requirements - support for delay of compliance date, RIN3170-AA95 - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan (PAL) programs for credit unions - recommend expanding the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales and Computer Employees, (RIN 1235-AA20) - supports the Department of Labors (DOL) proposed adjustments to overtime exemption rules under the Fair Labor Standards Act (FLSA) - urge DOL to consider additional options and guidance to reduce burdens for smaller credit unions - support regulatory flexibility for certain bonuses, incentive payments, and commissions - urge DOL to commit to a future formal assessment of the four-year review of the salary levels, in lieu of automatic reviews or increases; Ginnie Mae, Request for Input on Pooling Eligibility Changes - recommend that Ginnie Mae first allow the VA to complete its own evaluation of VA cash-out refinances, then closely evaluate other changes before removing cash out refinance loans made through the U.S. Department of Veterans Affairs from the Ginnie Mae II Multi-Issuer Program (GIIMIP) - Before excluding VA cash-out refinances, Ginnie Mae should complete further review to determine whether there is more than a correlation between the propensity to rapidly prepay VA loans and the different LTV requirements in the VA program compared to those of the Federal Housing Administration (FHA), Fannie Mae, and Freddie Mac - support a de minimis standard restricting inclusion of cash-out refinances for VA loans in the GII MIP; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws (RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; supports a strong independent NCUA; Consideration of the Financial Services and General Government Appropriations Bill - supports the language in the draft bill to keep funding for the NCUA's Community Development Revolving Loan Fund (CDRLF) at a level of $2 million and to fund the Community Development Financial Institutions (CDFI) Fund at a level of $300 million; NCUA should maintain the current regulation requiring annual review by a federal credit union (FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; A Review of the Appraisal Industry - a formal appraisal should not be required for commercial real estate appraisals; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; support amendment to the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act (COUNTER Act), HR 2514; support amendment to the Corporate Transparency Act of 2019, HR 2513; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support reform bill addressing beneficial ownership requirements; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans (RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases; support the SBAs modernizing the requirements for Certified Development Companies who provide vital 504 program loans; support Title IV of H.R. 3300, the Economic Mobility Act of 2019, which would repeal the 21 percent excise tax imposed on certain not-for-profits for providing certain fringe benefits under the Tax Cuts and Jobs Act (TCJA).; support 2019 NCUA Regulatory Review of 1/3 of NCUA regualtions;

Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.

Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support legislation such as H.R. 4067, the Financial Inclusion in Banking Act of 2019, which would direct the CFPBs Office of Community Affairs to research how to increase financial inclusion for underserved communities; supports CFPB Director Kathy Kraningers efforts to provide financial institutions with regulatory certainty and targeted relief, while focusing the CFPBs efforts on bad actors; support increased focus on diversity, equity, and inclusion (DEI) within the American economy and the industry; support laws and regulations aimed at detecting and preventing discrimination, as well as the legal mechanisms used to protect fundamental consumer interests; support HUDs objective of updating the Disparate Impact Rule by aligning it more closely with the Supreme Courts decision in Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc., (Inclusive Communities); support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support H.R. 2513, the Corporate Transparency Act of 2019 and the COUNTER Act of 2019; support efforts to modernize the Currency Transaction Report (CTR) threshold by indexing it for inflation; support The Business of Insurance Regulatory Reform Act of 2019; support tech sprints; support regulatory efforts to modernize and streamline supervisory processes; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; Support Interbank real-time gross settlement of faster payments docket No. OP-1670; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; advocate against an expanded consumer compliance examination program; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support implementing regulations that clarify that the requirements of the CCPA and its implementing regulations do not apply to organizations that solely collect GLBA-covered information; support a delay in enforcement of the CCPA; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; H.R. 5315, the Expanding Opportunity for MDIs Act, offered by Representative Joyce Beatty (D-OH) and H.R. 5322, the Ensuring Diversity in Community Banking Act of 2019; support keeping legislative reform of the housing finance system as a priority for the Senate Committee on Banking, Housing Committee on Banking, Housing & Urban Affairs and the House Committee on Financial Services; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; support S. 2563, the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings Act (ILLICIT CASH Act).

Protect the credit union tax exemption; S. 151, the TRACED Act - modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill - reforms should require voice service providers to consult with call originators as they implement the STIR/SHAKEN call authentication framework - require FCC to promulgate rules for the safe harbor available to voice service providers that establish a process to give notice to legitimate callers prior to their calls being blocked and, subsequently, correct any unintended blocking; establish a broad definition of automatic telephone dialing system or autodialer under the TCPA that only includes equipment that uses a random or sequential number generator to store or produce numbers and dial those numbers without human intervention - conduct reforms to help credit unions contact their members with important account information - permit callers to establish a reasonable opt-out method for revoking their consent to be contacted - remove language that goes beyond the scope of addressing the illegal actors who make abusive automated calls and in essence harms businesses and consumers by impeding legitimate calls that consumers actually need or want, HR 946 - support creating reassigned numbers database using existing numbering databases, (CG Docket No. 17-59) - provide a comprehensive safe harbor from TCPA liability for callers who use the database regularly but make a call to a reassigned number due to database errors - urge FCC to seek public comment on draft Declaratory Ruling, Advanced Methods to Target and Eliminate Unlawful Robocalls, (CG Docket No. 17-59, WC Docket No. 17-97); financial literacy - Support HR 275 and the goals and ideals of financial literacy month; Department of Defense - oppose an amendment to provide banks with rent-free leases on military bases under the John S. McCain National Defense Authorization Act - exempt loans to veteran-owned businesses from the credit union member business lending cap, HR 2305; Postal Banking - the United States Postal Service should not provide banking services which will be beyond its core competencies, will raise a number of serious regulatory and consumer protection questions, and will present significant competitive issues for private sector entities; Banking regulation and supervision - support the use of formal rulemaking versus informal guidance - agencies should clarify how guidance is treated, as inconsistencies can lead to compliance confusion; ensure that examiners treat regulations and guidance consistently - improve the examination process for financial institutions by passing the Financial Institutions Examination Fairness and Reform Act; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time; Supervisory Committee Audits and Verifications (RIN 3133-AE91) - NCUA should remove the report on examination of internal controls over call reporting alternative audit option - remove the 120-day language in engagement letters to outside, compensated auditors regarding the required written report - support Appendix A to Part 715 alternative audit option - do not include other areas of review in Appendix A - retain Supervisory Committee Guide; Request for Information Regarding Consumer Credit Card Market (Docket No. CFPB-2019-0002) - encourage effective credit card disclosure use, including flexibility to provide required disclosures via mobile banking platforms - support providing fair and transparent credit products and services - support changes to regulations carrying out the Credit Card Accountability Responsibility and Disclosure Act of 2009 as the consumer credit card market evolves - support reporting on the credit card market to ensure practices align with CARD Act - support effective, simple and user friendly credit card disclosures - support allocating resources from Office of Cost-Benefit Analysis toward innovation; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; oppose the Green Amendment (#29) to H.R. 1500 which would reinstate the CFPBs rule on arbitration agreements which Congress voted to disapprove in 2017; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; Property Assessed Clean Energy Loans - support imposing ability-to-repay underwriting requirements for PACE loans - support imposing civil liability on violators of the ATR requirements under section 130 of the Truth In Lending Act - support adopting Truth In Lending - RESPA disclosures for PACE loans; Payday, Vehicle Title, and Certain High-Cost Installment Loans (RIN 3170-AA80) - support rescission of mandatory ability-to-repay (ATR) underwriting requirements - support for delay of compliance date, RIN3170-AA95 - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan (PAL) programs for credit unions - recommend expanding the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales and Computer Employees, (RIN 1235-AA20) - supports the Department of Labors (DOL) proposed adjustments to overtime exemption rules under the Fair Labor Standards Act (FLSA) - urge DOL to consider additional options and guidance to reduce burdens for smaller credit unions - support regulatory flexibility for certain bonuses, incentive payments, and commissions - urge DOL to commit to a future formal assessment of the four-year review of the salary levels, in lieu of automatic reviews or increases; Ginnie Mae, Request for Input on Pooling Eligibility Changes - recommend that Ginnie Mae first allow the VA to complete its own evaluation of VA cash-out refinances, then closely evaluate other changes before removing cash out refinance loans made through the U.S. Department of Veterans Affairs from the Ginnie Mae II Multi-Issuer Program (GIIMIP) - Before excluding VA cash-out refinances, Ginnie Mae should complete further review to determine whether there is more than a correlation between the propensity to rapidly prepay VA loans and the different LTV requirements in the VA program compared to those of the Federal Housing Administration (FHA), Fannie Mae, and Freddie Mac - support a de minimis standard restricting inclusion of cash-out refinances for VA loans in the GII MIP; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws (RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; supports a strong independent NCUA; Consideration of the Financial Services and General Government Appropriations Bill - supports the language in the draft bill to keep funding for the NCUA's Community Development Revolving Loan Fund (CDRLF) at a level of $2 million and to fund the Community Development Financial Institutions (CDFI) Fund at a level of $300 million; NCUA should maintain the current regulation requiring annual review by a federal credit union (FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; A Review of the Appraisal Industry - a formal appraisal should not be required for commercial real estate appraisals; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; support amendment to the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act (COUNTER Act), HR 2514; support amendment to the Corporate Transparency Act of 2019, HR 2513; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support reform bill addressing beneficial ownership requirements; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans (RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases; support the SBAs modernizing the requirements for Certified Development Companies who provide vital 504 program loans; support Title IV of H.R. 3300, the Economic Mobility Act of 2019, which would repeal the 21 percent excise tax imposed on certain not-for-profits for providing certain fringe benefits under the Tax Cuts and Jobs Act (TCJA).; support 2019 NCUA Regulatory Review of 1/3 of NCUA regulations.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support legislation such as H.R. 4067, the Financial Inclusion in Banking Act of 2019, which would direct the CFPBs Office of Community Affairs to research how to increase financial inclusion for underserved communities; supports CFPB Director Kathy Kraningers efforts to provide financial institutions with regulatory certainty and targeted relief, while focusing the CFPBs efforts on bad actors; support increased focus on diversity, equity, and inclusion (DEI) within the American economy and the industry; support laws and regulations aimed at detecting and preventing discrimination, as well as the legal mechanisms used to protect fundamental consumer interests; support HUDs objective of updating the Disparate Impact Rule by aligning it more closely with the Supreme Courts decision in Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc., (Inclusive Communities); support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support H.R. 2513, the Corporate Transparency Act of 2019 and the COUNTER Act of 2019; support efforts to modernize the Currency Transaction Report (CTR) threshold by indexing it for inflation; support The Business of Insurance Regulatory Reform Act of 2019; support tech sprints; support regulatory efforts to modernize and streamline supervisory processes; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; Support Interbank real-time gross settlement of faster payments docket No. OP-1670; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; advocate against an expanded consumer compliance examination program; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support implementing regulations that clarify that the requirements of the CCPA and its implementing regulations do not apply to organizations that solely collect GLBA-covered information; support a delay in enforcement of the CCPA; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; H.R. 5315, the Expanding Opportunity for MDIs Act, offered by Representative Joyce Beatty (D-OH) and H.R. 5322, the Ensuring Diversity in Community Banking Act of 2019; support keeping legislative reform of the housing finance system as a priority for the Senate Committee on Banking, Housing Committee on Banking, Housing & Urban Affairs and the House Committee on Financial Services; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; support S. 2563, the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings Act (ILLICIT CASH Act).

Protect the credit union tax exemption; S. 151, the TRACED Act - modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill - reforms should require voice service providers to consult with call originators as they implement the STIR/SHAKEN call authentication framework - require FCC to promulgate rules for the safe harbor available to voice service providers that establish a process to give notice to legitimate callers prior to their calls being blocked and, subsequently, correct any unintended blocking; establish a broad definition of automatic telephone dialing system or autodialer under the TCPA that only includes equipment that uses a random or sequential number generator to store or produce numbers and dial those numbers without human intervention - conduct reforms to help credit unions contact their members with important account information - permit callers to establish a reasonable opt-out method for revoking their consent to be contacted - remove language that goes beyond the scope of addressing the illegal actors who make abusive automated calls and in essence harms businesses and consumers by impeding legitimate calls that consumers actually need or want, HR 946 - support creating reassigned numbers database using existing numbering databases, (CG Docket No. 17-59) - provide a comprehensive safe harbor from TCPA liability for callers who use the database regularly but make a call to a reassigned number due to database errors - urge FCC to seek public comment on draft Declaratory Ruling, Advanced Methods to Target and Eliminate Unlawful Robocalls, (CG Docket No. 17-59, WC Docket No. 17-97); financial literacy - Support HR 275 and the goals and ideals of financial literacy month; Department of Defense - oppose an amendment to provide banks with rent-free leases on military bases under the John S. McCain National Defense Authorization Act - exempt loans to veteran-owned businesses from the credit union member business lending cap, HR 2305; Postal Banking - the United States Postal Service should not provide banking services which will be beyond its core competencies, will raise a number of serious regulatory and consumer protection questions, and will present significant competitive issues for private sector entities; Banking regulation and supervision - support the use of formal rulemaking versus informal guidance - agencies should clarify how guidance is treated, as inconsistencies can lead to compliance confusion; ensure that examiners treat regulations and guidance consistently - improve the examination process for financial institutions by passing the Financial Institutions Examination Fairness and Reform Act; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time; Supervisory Committee Audits and Verifications (RIN 3133-AE91) - NCUA should remove the report on examination of internal controls over call reporting alternative audit option - remove the 120-day language in engagement letters to outside, compensated auditors regarding the required written report - support Appendix A to Part 715 alternative audit option - do not include other areas of review in Appendix A - retain Supervisory Committee Guide; Request for Information Regarding Consumer Credit Card Market (Docket No. CFPB-2019-0002) - encourage effective credit card disclosure use, including flexibility to provide required disclosures via mobile banking platforms - support providing fair and transparent credit products and services - support changes to regulations carrying out the Credit Card Accountability Responsibility and Disclosure Act of 2009 as the consumer credit card market evolves - support reporting on the credit card market to ensure practices align with CARD Act - support effective, simple and user friendly credit card disclosures - support allocating resources from Office of Cost-Benefit Analysis toward innovation; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; oppose the Green Amendment (#29) to H.R. 1500 which would reinstate the CFPBs rule on arbitration agreements which Congress voted to disapprove in 2017; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; Property Assessed Clean Energy Loans - support imposing ability-to-repay underwriting requirements for PACE loans - support imposing civil liability on violators of the ATR requirements under section 130 of the Truth In Lending Act - support adopting Truth In Lending - RESPA disclosures for PACE loans; Payday, Vehicle Title, and Certain High-Cost Installment Loans (RIN 3170-AA80) - support rescission of mandatory ability-to-repay (ATR) underwriting requirements - support for delay of compliance date, RIN3170-AA95 - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan (PAL) programs for credit unions - recommend expanding the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales and Computer Employees, (RIN 1235-AA20) - supports the Department of Labors (DOL) proposed adjustments to overtime exemption rules under the Fair Labor Standards Act (FLSA) - urge DOL to consider additional options and guidance to reduce burdens for smaller credit unions - support regulatory flexibility for certain bonuses, incentive payments, and commissions - urge DOL to commit to a future formal assessment of the four-year review of the salary levels, in lieu of automatic reviews or increases; Ginnie Mae, Request for Input on Pooling Eligibility Changes - recommend that Ginnie Mae first allow the VA to complete its own evaluation of VA cash-out refinances, then closely evaluate other changes before removing cash out refinance loans made through the U.S. Department of Veterans Affairs from the Ginnie Mae II Multi-Issuer Program (GIIMIP) - Before excluding VA cash-out refinances, Ginnie Mae should complete further review to determine whether there is more than a correlation between the propensity to rapidly prepay VA loans and the different LTV requirements in the VA program compared to those of the Federal Housing Administration (FHA), Fannie Mae, and Freddie Mac - support a de minimis standard restricting inclusion of cash-out refinances for VA loans in the GII MIP; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws (RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; supports a strong independent NCUA; Consideration of the Financial Services and General Government Appropriations Bill - supports the language in the draft bill to keep funding for the NCUA's Community Development Revolving Loan Fund (CDRLF) at a level of $2 million and to fund the Community Development Financial Institutions (CDFI) Fund at a level of $300 million; NCUA should maintain the current regulation requiring annual review by a federal credit union (FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; A Review of the Appraisal Industry - a formal appraisal should not be required for commercial real estate appraisals; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; support amendment to the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act (COUNTER Act), HR 2514; support amendment to the Corporate Transparency Act of 2019, HR 2513; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support reform bill addressing beneficial ownership requirements; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans (RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases; support the SBAs modernizing the requirements for Certified Development Companies who provide vital 504 program loans; support Title IV of H.R. 3300, the Economic Mobility Act of 2019, which would repeal the 21 percent excise tax imposed on certain not-for-profits for providing certain fringe benefits under the Tax Cuts and Jobs Act (TCJA).; support 2019 NCUA Regulatory Review of 1/3 of NCUA regualtions;

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support legislation such as H.R. 4067, the Financial Inclusion in Banking Act of 2019, which would direct the CFPBs Office of Community Affairs to research how to increase financial inclusion for underserved communities; supports CFPB Director Kathy Kraningers efforts to provide financial institutions with regulatory certainty and targeted relief, while focusing the CFPBs efforts on bad actors; support increased focus on diversity, equity, and inclusion (DEI) within the American economy and the industry; support laws and regulations aimed at detecting and preventing discrimination, as well as the legal mechanisms used to protect fundamental consumer interests; support HUDs objective of updating the Disparate Impact Rule by aligning it more closely with the Supreme Courts decision in Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc., (Inclusive Communities); support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support H.R. 2513, the Corporate Transparency Act of 2019 and the COUNTER Act of 2019; support efforts to modernize the Currency Transaction Report (CTR) threshold by indexing it for inflation; support The Business of Insurance Regulatory Reform Act of 2019; support tech sprints; support regulatory efforts to modernize and streamline supervisory processes; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; Support Interbank real-time gross settlement of faster payments docket No. OP-1670; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; advocate against an expanded consumer compliance examination program; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support implementing regulations that clarify that the requirements of the CCPA and its implementing regulations do not apply to organizations that solely collect GLBA-covered information; support a delay in enforcement of the CCPA; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; H.R. 5315, the Expanding Opportunity for MDIs Act, offered by Representative Joyce Beatty (D-OH) and H.R. 5322, the Ensuring Diversity in Community Banking Act of 2019; support keeping legislative reform of the housing finance system as a priority for the Senate Committee on Banking, Housing Committee on Banking, Housing & Urban Affairs and the House Committee on Financial Services; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; support S. 2563, the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings Act (ILLICIT CASH Act).

Protect the credit union tax exemption; S. 151, the TRACED Act - modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill - reforms should require voice service providers to consult with call originators as they implement the STIR/SHAKEN call authentication framework - require FCC to promulgate rules for the safe harbor available to voice service providers that establish a process to give notice to legitimate callers prior to their calls being blocked and, subsequently, correct any unintended blocking; establish a broad definition of automatic telephone dialing system or autodialer under the TCPA that only includes equipment that uses a random or sequential number generator to store or produce numbers and dial those numbers without human intervention - conduct reforms to help credit unions contact their members with important account information - permit callers to establish a reasonable opt-out method for revoking their consent to be contacted - remove language that goes beyond the scope of addressing the illegal actors who make abusive automated calls and in essence harms businesses and consumers by impeding legitimate calls that consumers actually need or want, HR 946 - support creating reassigned numbers database using existing numbering databases, (CG Docket No. 17-59) - provide a comprehensive safe harbor from TCPA liability for callers who use the database regularly but make a call to a reassigned number due to database errors - urge FCC to seek public comment on draft Declaratory Ruling, Advanced Methods to Target and Eliminate Unlawful Robocalls, (CG Docket No. 17-59, WC Docket No. 17-97); financial literacy - Support HR 275 and the goals and ideals of financial literacy month; Department of Defense - oppose an amendment to provide banks with rent-free leases on military bases under the John S. McCain National Defense Authorization Act - exempt loans to veteran-owned businesses from the credit union member business lending cap, HR 2305; Postal Banking - the United States Postal Service should not provide banking services which will be beyond its core competencies, will raise a number of serious regulatory and consumer protection questions, and will present significant competitive issues for private sector entities; Banking regulation and supervision - support the use of formal rulemaking versus informal guidance - agencies should clarify how guidance is treated, as inconsistencies can lead to compliance confusion; ensure that examiners treat regulations and guidance consistently - improve the examination process for financial institutions by passing the Financial Institutions Examination Fairness and Reform Act; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time; Supervisory Committee Audits and Verifications (RIN 3133-AE91) - NCUA should remove the report on examination of internal controls over call reporting alternative audit option - remove the 120-day language in engagement letters to outside, compensated auditors regarding the required written report - support Appendix A to Part 715 alternative audit option - do not include other areas of review in Appendix A - retain Supervisory Committee Guide; Request for Information Regarding Consumer Credit Card Market (Docket No. CFPB-2019-0002) - encourage effective credit card disclosure use, including flexibility to provide required disclosures via mobile banking platforms - support providing fair and transparent credit products and services - support changes to regulations carrying out the Credit Card Accountability Responsibility and Disclosure Act of 2009 as the consumer credit card market evolves - support reporting on the credit card market to ensure practices align with CARD Act - support effective, simple and user friendly credit card disclosures - support allocating resources from Office of Cost-Benefit Analysis toward innovation; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; oppose the Green Amendment (#29) to H.R. 1500 which would reinstate the CFPBs rule on arbitration agreements which Congress voted to disapprove in 2017; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; Property Assessed Clean Energy Loans - support imposing ability-to-repay underwriting requirements for PACE loans - support imposing civil liability on violators of the ATR requirements under section 130 of the Truth In Lending Act - support adopting Truth In Lending - RESPA disclosures for PACE loans; Payday, Vehicle Title, and Certain High-Cost Installment Loans (RIN 3170-AA80) - support rescission of mandatory ability-to-repay (ATR) underwriting requirements - support for delay of compliance date, RIN3170-AA95 - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan (PAL) programs for credit unions - recommend expanding the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales and Computer Employees, (RIN 1235-AA20) - supports the Department of Labors (DOL) proposed adjustments to overtime exemption rules under the Fair Labor Standards Act (FLSA) - urge DOL to consider additional options and guidance to reduce burdens for smaller credit unions - support regulatory flexibility for certain bonuses, incentive payments, and commissions - urge DOL to commit to a future formal assessment of the four-year review of the salary levels, in lieu of automatic reviews or increases; Ginnie Mae, Request for Input on Pooling Eligibility Changes - recommend that Ginnie Mae first allow the VA to complete its own evaluation of VA cash-out refinances, then closely evaluate other changes before removing cash out refinance loans made through the U.S. Department of Veterans Affairs from the Ginnie Mae II Multi-Issuer Program (GIIMIP) - Before excluding VA cash-out refinances, Ginnie Mae should complete further review to determine whether there is more than a correlation between the propensity to rapidly prepay VA loans and the different LTV requirements in the VA program compared to those of the Federal Housing Administration (FHA), Fannie Mae, and Freddie Mac - support a de minimis standard restricting inclusion of cash-out refinances for VA loans in the GII MIP; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws (RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; supports a strong independent NCUA; Consideration of the Financial Services and General Government Appropriations Bill - supports the language in the draft bill to keep funding for the NCUA's Community Development Revolving Loan Fund (CDRLF) at a level of $2 million and to fund the Community Development Financial Institutions (CDFI) Fund at a level of $300 million; NCUA should maintain the current regulation requiring annual review by a federal credit union (FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; A Review of the Appraisal Industry - a formal appraisal should not be required for commercial real estate appraisals; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; support amendment to the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act (COUNTER Act), HR 2514; support amendment to the Corporate Transparency Act of 2019, HR 2513; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support reform bill addressing beneficial ownership requirements; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans (RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases; support the SBAs modernizing the requirements for Certified Development Companies who provide vital 504 program loans; support Title IV of H.R. 3300, the Economic Mobility Act of 2019, which would repeal the 21 percent excise tax imposed on certain not-for-profits for providing certain fringe benefits under the Tax Cuts and Jobs Act (TCJA).; support 2019 NCUA Regulatory Review of 1/3 of NCUA regulations.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support legislation such as H.R. 4067, the Financial Inclusion in Banking Act of 2019, which would direct the CFPBs Office of Community Affairs to research how to increase financial inclusion for underserved communities; supports CFPB Director Kathy Kraningers efforts to provide financial institutions with regulatory certainty and targeted relief, while focusing the CFPBs efforts on bad actors; support increased focus on diversity, equity, and inclusion (DEI) within the American economy and the industry; support laws and regulations aimed at detecting and preventing discrimination, as well as the legal mechanisms used to protect fundamental consumer interests; support HUDs objective of updating the Disparate Impact Rule by aligning it more closely with the Supreme Courts decision in Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc., (Inclusive Communities); support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support H.R. 2513, the Corporate Transparency Act of 2019 and the COUNTER Act of 2019; support efforts to modernize the Currency Transaction Report (CTR) threshold by indexing it for inflation; support The Business of Insurance Regulatory Reform Act of 2019; support tech sprints; support regulatory efforts to modernize and streamline supervisory processes; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; Support Interbank real-time gross settlement of faster payments docket No. OP-1670; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; advocate against an expanded consumer compliance examination program; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support implementing regulations that clarify that the requirements of the CCPA and its implementing regulations do not apply to organizations that solely collect GLBA-covered information; support a delay in enforcement of the CCPA; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; H.R. 5315, the Expanding Opportunity for MDIs Act, offered by Representative Joyce Beatty (D-OH) and H.R. 5322, the Ensuring Diversity in Community Banking Act of 2019; support keeping legislative reform of the housing finance system as a priority for the Senate Committee on Banking, Housing Committee on Banking, Housing & Urban Affairs and the House Committee on Financial Services; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; support S. 2563, the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings Act (ILLICIT CASH Act).

Protect the credit union tax exemption; S. 151, the TRACED Act - modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill - reforms should require voice service providers to consult with call originators as they implement the STIR/SHAKEN call authentication framework - require FCC to promulgate rules for the safe harbor available to voice service providers that establish a process to give notice to legitimate callers prior to their calls being blocked and, subsequently, correct any unintended blocking; establish a broad definition of automatic telephone dialing system or autodialer under the TCPA that only includes equipment that uses a random or sequential number generator to store or produce numbers and dial those numbers without human intervention - conduct reforms to help credit unions contact their members with important account information - permit callers to establish a reasonable opt-out method for revoking their consent to be contacted - remove language that goes beyond the scope of addressing the illegal actors who make abusive automated calls and in essence harms businesses and consumers by impeding legitimate calls that consumers actually need or want, HR 946 - support creating reassigned numbers database using existing numbering databases, (CG Docket No. 17-59) - provide a comprehensive safe harbor from TCPA liability for callers who use the database regularly but make a call to a reassigned number due to database errors - urge FCC to seek public comment on draft Declaratory Ruling, Advanced Methods to Target and Eliminate Unlawful Robocalls, (CG Docket No. 17-59, WC Docket No. 17-97); financial literacy - Support HR 275 and the goals and ideals of financial literacy month; Department of Defense - oppose an amendment to provide banks with rent-free leases on military bases under the John S. McCain National Defense Authorization Act - exempt loans to veteran-owned businesses from the credit union member business lending cap, HR 2305; Postal Banking - the United States Postal Service should not provide banking services which will be beyond its core competencies, will raise a number of serious regulatory and consumer protection questions, and will present significant competitive issues for private sector entities; Banking regulation and supervision - support the use of formal rulemaking versus informal guidance - agencies should clarify how guidance is treated, as inconsistencies can lead to compliance confusion; ensure that examiners treat regulations and guidance consistently - improve the examination process for financial institutions by passing the Financial Institutions Examination Fairness and Reform Act; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time; Supervisory Committee Audits and Verifications (RIN 3133-AE91) - NCUA should remove the report on examination of internal controls over call reporting alternative audit option - remove the 120-day language in engagement letters to outside, compensated auditors regarding the required written report - support Appendix A to Part 715 alternative audit option - do not include other areas of review in Appendix A - retain Supervisory Committee Guide; Request for Information Regarding Consumer Credit Card Market (Docket No. CFPB-2019-0002) - encourage effective credit card disclosure use, including flexibility to provide required disclosures via mobile banking platforms - support providing fair and transparent credit products and services - support changes to regulations carrying out the Credit Card Accountability Responsibility and Disclosure Act of 2009 as the consumer credit card market evolves - support reporting on the credit card market to ensure practices align with CARD Act - support effective, simple and user friendly credit card disclosures - support allocating resources from Office of Cost-Benefit Analysis toward innovation; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; oppose the Green Amendment (#29) to H.R. 1500 which would reinstate the CFPBs rule on arbitration agreements which Congress voted to disapprove in 2017; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; Property Assessed Clean Energy Loans - support imposing ability-to-repay underwriting requirements for PACE loans - support imposing civil liability on violators of the ATR requirements under section 130 of the Truth In Lending Act - support adopting Truth In Lending - RESPA disclosures for PACE loans; Payday, Vehicle Title, and Certain High-Cost Installment Loans (RIN 3170-AA80) - support rescission of mandatory ability-to-repay (ATR) underwriting requirements - support for delay of compliance date, RIN3170-AA95 - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan (PAL) programs for credit unions - recommend expanding the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales and Computer Employees, (RIN 1235-AA20) - supports the Department of Labors (DOL) proposed adjustments to overtime exemption rules under the Fair Labor Standards Act (FLSA) - urge DOL to consider additional options and guidance to reduce burdens for smaller credit unions - support regulatory flexibility for certain bonuses, incentive payments, and commissions - urge DOL to commit to a future formal assessment of the four-year review of the salary levels, in lieu of automatic reviews or increases; Ginnie Mae, Request for Input on Pooling Eligibility Changes - recommend that Ginnie Mae first allow the VA to complete its own evaluation of VA cash-out refinances, then closely evaluate other changes before removing cash out refinance loans made through the U.S. Department of Veterans Affairs from the Ginnie Mae II Multi-Issuer Program (GIIMIP) - Before excluding VA cash-out refinances, Ginnie Mae should complete further review to determine whether there is more than a correlation between the propensity to rapidly prepay VA loans and the different LTV requirements in the VA program compared to those of the Federal Housing Administration (FHA), Fannie Mae, and Freddie Mac - support a de minimis standard restricting inclusion of cash-out refinances for VA loans in the GII MIP; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws (RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; supports a strong independent NCUA; Consideration of the Financial Services and General Government Appropriations Bill - supports the language in the draft bill to keep funding for the NCUA's Community Development Revolving Loan Fund (CDRLF) at a level of $2 million and to fund the Community Development Financial Institutions (CDFI) Fund at a level of $300 million; NCUA should maintain the current regulation requiring annual review by a federal credit union (FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; A Review of the Appraisal Industry - a formal appraisal should not be required for commercial real estate appraisals; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; support amendment to the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act (COUNTER Act), HR 2514; support amendment to the Corporate Transparency Act of 2019, HR 2513; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support reform bill addressing beneficial ownership requirements; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans (RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases; support the SBAs modernizing the requirements for Certified Development Companies who provide vital 504 program loans; support Title IV of H.R. 3300, the Economic Mobility Act of 2019, which would repeal the 21 percent excise tax imposed on certain not-for-profits for providing certain fringe benefits under the Tax Cuts and Jobs Act (TCJA).; support 2019 NCUA Regulatory Review of 1/3 of NCUA regualtions;

Protect the credit union tax exemption; S. 151, the TRACED Act - modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill - reforms should require voice service providers to consult with call originators as they implement the STIR/SHAKEN call authentication framework - require FCC to promulgate rules for the safe harbor available to voice service providers that establish a process to give notice to legitimate callers prior to their calls being blocked and, subsequently, correct any unintended blocking; establish a broad definition of automatic telephone dialing system or autodialer under the TCPA that only includes equipment that uses a random or sequential number generator to store or produce numbers and dial those numbers without human intervention - conduct reforms to help credit unions contact their members with important account information - permit callers to establish a reasonable opt-out method for revoking their consent to be contacted - remove language that goes beyond the scope of addressing the illegal actors who make abusive automated calls and in essence harms businesses and consumers by impeding legitimate calls that consumers actually need or want, HR 946 - support creating reassigned numbers database using existing numbering databases, (CG Docket No. 17-59) - provide a comprehensive safe harbor from TCPA liability for callers who use the database regularly but make a call to a reassigned number due to database errors - urge FCC to seek public comment on draft Declaratory Ruling, Advanced Methods to Target and Eliminate Unlawful Robocalls, (CG Docket No. 17-59, WC Docket No. 17-97); financial literacy - Support HR 275 and the goals and ideals of financial literacy month; Department of Defense - oppose an amendment to provide banks with rent-free leases on military bases under the John S. McCain National Defense Authorization Act - exempt loans to veteran-owned businesses from the credit union member business lending cap, HR 2305; Postal Banking - the United States Postal Service should not provide banking services which will be beyond its core competencies, will raise a number of serious regulatory and consumer protection questions, and will present significant competitive issues for private sector entities; Banking regulation and supervision - support the use of formal rulemaking versus informal guidance - agencies should clarify how guidance is treated, as inconsistencies can lead to compliance confusion; ensure that examiners treat regulations and guidance consistently - improve the examination process for financial institutions by passing the Financial Institutions Examination Fairness and Reform Act; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time; Supervisory Committee Audits and Verifications (RIN 3133-AE91) - NCUA should remove the report on examination of internal controls over call reporting alternative audit option - remove the 120-day language in engagement letters to outside, compensated auditors regarding the required written report - support Appendix A to Part 715 alternative audit option - do not include other areas of review in Appendix A - retain Supervisory Committee Guide; Request for Information Regarding Consumer Credit Card Market (Docket No. CFPB-2019-0002) - encourage effective credit card disclosure use, including flexibility to provide required disclosures via mobile banking platforms - support providing fair and transparent credit products and services - support changes to regulations carrying out the Credit Card Accountability Responsibility and Disclosure Act of 2009 as the consumer credit card market evolves - support reporting on the credit card market to ensure practices align with CARD Act - support effective, simple and user friendly credit card disclosures - support allocating resources from Office of Cost-Benefit Analysis toward innovation; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; oppose the Green Amendment (#29) to H.R. 1500 which would reinstate the CFPBs rule on arbitration agreements which Congress voted to disapprove in 2017; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; Property Assessed Clean Energy Loans - support imposing ability-to-repay underwriting requirements for PACE loans - support imposing civil liability on violators of the ATR requirements under section 130 of the Truth In Lending Act - support adopting Truth In Lending - RESPA disclosures for PACE loans; Payday, Vehicle Title, and Certain High-Cost Installment Loans (RIN 3170-AA80) - support rescission of mandatory ability-to-repay (ATR) underwriting requirements - support for delay of compliance date, RIN3170-AA95 - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan (PAL) programs for credit unions - recommend expanding the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales and Computer Employees, (RIN 1235-AA20) - supports the Department of Labors (DOL) proposed adjustments to overtime exemption rules under the Fair Labor Standards Act (FLSA) - urge DOL to consider additional options and guidance to reduce burdens for smaller credit unions - support regulatory flexibility for certain bonuses, incentive payments, and commissions - urge DOL to commit to a future formal assessment of the four-year review of the salary levels, in lieu of automatic reviews or increases; Ginnie Mae, Request for Input on Pooling Eligibility Changes - recommend that Ginnie Mae first allow the VA to complete its own evaluation of VA cash-out refinances, then closely evaluate other changes before removing cash out refinance loans made through the U.S. Department of Veterans Affairs from the Ginnie Mae II Multi-Issuer Program (GIIMIP) - Before excluding VA cash-out refinances, Ginnie Mae should complete further review to determine whether there is more than a correlation between the propensity to rapidly prepay VA loans and the different LTV requirements in the VA program compared to those of the Federal Housing Administration (FHA), Fannie Mae, and Freddie Mac - support a de minimis standard restricting inclusion of cash-out refinances for VA loans in the GII MIP; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws (RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; supports a strong independent NCUA; Consideration of the Financial Services and General Government Appropriations Bill - supports the language in the draft bill to keep funding for the NCUA's Community Development Revolving Loan Fund (CDRLF) at a level of $2 million and to fund the Community Development Financial Institutions (CDFI) Fund at a level of $300 million; NCUA should maintain the current regulation requiring annual review by a federal credit union (FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; A Review of the Appraisal Industry - a formal appraisal should not be required for commercial real estate appraisals; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; support amendment to the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act (COUNTER Act), HR 2514; support amendment to the Corporate Transparency Act of 2019, HR 2513; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support reform bill addressing beneficial ownership requirements; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans (RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases; support the SBAs modernizing the requirements for Certified Development Companies who provide vital 504 program loans; support Title IV of H.R. 3300, the Economic Mobility Act of 2019, which would repeal the 21 percent excise tax imposed on certain not-for-profits for providing certain fringe benefits under the Tax Cuts and Jobs Act (TCJA).; support 2019 NCUA Regulatory Review of 1/3 of NCUA regualtions;

Protect the credit union tax exemption; S. 151, the TRACED Act - modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill - reforms should require voice service providers to consult with call originators as they implement the STIR/SHAKEN call authentication framework - require FCC to promulgate rules for the safe harbor available to voice service providers that establish a process to give notice to legitimate callers prior to their calls being blocked and, subsequently, correct any unintended blocking; establish a broad definition of automatic telephone dialing system or autodialer under the TCPA that only includes equipment that uses a random or sequential number generator to store or produce numbers and dial those numbers without human intervention - conduct reforms to help credit unions contact their members with important account information - permit callers to establish a reasonable opt-out method for revoking their consent to be contacted - remove language that goes beyond the scope of addressing the illegal actors who make abusive automated calls and in essence harms businesses and consumers by impeding legitimate calls that consumers actually need or want, HR 946 - support creating reassigned numbers database using existing numbering databases, (CG Docket No. 17-59) - provide a comprehensive safe harbor from TCPA liability for callers who use the database regularly but make a call to a reassigned number due to database errors - urge FCC to seek public comment on draft Declaratory Ruling, Advanced Methods to Target and Eliminate Unlawful Robocalls, (CG Docket No. 17-59, WC Docket No. 17-97); financial literacy - Support HR 275 and the goals and ideals of financial literacy month; Department of Defense - oppose an amendment to provide banks with rent-free leases on military bases under the John S. McCain National Defense Authorization Act - exempt loans to veteran-owned businesses from the credit union member business lending cap, HR 2305; Postal Banking - the United States Postal Service should not provide banking services which will be beyond its core competencies, will raise a number of serious regulatory and consumer protection questions, and will present significant competitive issues for private sector entities; Banking regulation and supervision - support the use of formal rulemaking versus informal guidance - agencies should clarify how guidance is treated, as inconsistencies can lead to compliance confusion; ensure that examiners treat regulations and guidance consistently - improve the examination process for financial institutions by passing the Financial Institutions Examination Fairness and Reform Act; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time; Supervisory Committee Audits and Verifications (RIN 3133-AE91) - NCUA should remove the report on examination of internal controls over call reporting alternative audit option - remove the 120-day language in engagement letters to outside, compensated auditors regarding the required written report - support Appendix A to Part 715 alternative audit option - do not include other areas of review in Appendix A - retain Supervisory Committee Guide; Request for Information Regarding Consumer Credit Card Market (Docket No. CFPB-2019-0002) - encourage effective credit card disclosure use, including flexibility to provide required disclosures via mobile banking platforms - support providing fair and transparent credit products and services - support changes to regulations carrying out the Credit Card Accountability Responsibility and Disclosure Act of 2009 as the consumer credit card market evolves - support reporting on the credit card market to ensure practices align with CARD Act - support effective, simple and user friendly credit card disclosures - support allocating resources from Office of Cost-Benefit Analysis toward innovation; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; oppose the Green Amendment (#29) to H.R. 1500 which would reinstate the CFPBs rule on arbitration agreements which Congress voted to disapprove in 2017; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; Property Assessed Clean Energy Loans - support imposing ability-to-repay underwriting requirements for PACE loans - support imposing civil liability on violators of the ATR requirements under section 130 of the Truth In Lending Act - support adopting Truth In Lending - RESPA disclosures for PACE loans; Payday, Vehicle Title, and Certain High-Cost Installment Loans (RIN 3170-AA80) - support rescission of mandatory ability-to-repay (ATR) underwriting requirements - support for delay of compliance date, RIN3170-AA95 - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan (PAL) programs for credit unions - recommend expanding the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales and Computer Employees, (RIN 1235-AA20) - supports the Department of Labors (DOL) proposed adjustments to overtime exemption rules under the Fair Labor Standards Act (FLSA) - urge DOL to consider additional options and guidance to reduce burdens for smaller credit unions - support regulatory flexibility for certain bonuses, incentive payments, and commissions - urge DOL to commit to a future formal assessment of the four-year review of the salary levels, in lieu of automatic reviews or increases; Ginnie Mae, Request for Input on Pooling Eligibility Changes - recommend that Ginnie Mae first allow the VA to complete its own evaluation of VA cash-out refinances, then closely evaluate other changes before removing cash out refinance loans made through the U.S. Department of Veterans Affairs from the Ginnie Mae II Multi-Issuer Program (GIIMIP) - Before excluding VA cash-out refinances, Ginnie Mae should complete further review to determine whether there is more than a correlation between the propensity to rapidly prepay VA loans and the different LTV requirements in the VA program compared to those of the Federal Housing Administration (FHA), Fannie Mae, and Freddie Mac - support a de minimis standard restricting inclusion of cash-out refinances for VA loans in the GII MIP; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws (RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; supports a strong independent NCUA; Consideration of the Financial Services and General Government Appropriations Bill - supports the language in the draft bill to keep funding for the NCUA's Community Development Revolving Loan Fund (CDRLF) at a level of $2 million and to fund the Community Development Financial Institutions (CDFI) Fund at a level of $300 million; NCUA should maintain the current regulation requiring annual review by a federal credit union (FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; A Review of the Appraisal Industry - a formal appraisal should not be required for commercial real estate appraisals; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; support amendment to the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act (COUNTER Act), HR 2514; support amendment to the Corporate Transparency Act of 2019, HR 2513; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support reform bill addressing beneficial ownership requirements; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans (RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases; support the SBAs modernizing the requirements for Certified Development Companies who provide vital 504 program loans; support Title IV of H.R. 3300, the Economic Mobility Act of 2019, which would repeal the 21 percent excise tax imposed on certain not-for-profits for providing certain fringe benefits under the Tax Cuts and Jobs Act (TCJA).; support 2019 NCUA Regulatory Review of 1/3 of NCUA regulations.

Protect the credit union tax exemption; S. 151, the TRACED Act - modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill - reforms should require voice service providers to consult with call originators as they implement the STIR/SHAKEN call authentication framework - require FCC to promulgate rules for the safe harbor available to voice service providers that establish a process to give notice to legitimate callers prior to their calls being blocked and, subsequently, correct any unintended blocking; establish a broad definition of automatic telephone dialing system or autodialer under the TCPA that only includes equipment that uses a random or sequential number generator to store or produce numbers and dial those numbers without human intervention - conduct reforms to help credit unions contact their members with important account information - permit callers to establish a reasonable opt-out method for revoking their consent to be contacted - remove language that goes beyond the scope of addressing the illegal actors who make abusive automated calls and in essence harms businesses and consumers by impeding legitimate calls that consumers actually need or want, HR 946 - support creating reassigned numbers database using existing numbering databases, (CG Docket No. 17-59) - provide a comprehensive safe harbor from TCPA liability for callers who use the database regularly but make a call to a reassigned number due to database errors - urge FCC to seek public comment on draft Declaratory Ruling, Advanced Methods to Target and Eliminate Unlawful Robocalls, (CG Docket No. 17-59, WC Docket No. 17-97); financial literacy - Support HR 275 and the goals and ideals of financial literacy month; Department of Defense - oppose an amendment to provide banks with rent-free leases on military bases under the John S. McCain National Defense Authorization Act - exempt loans to veteran-owned businesses from the credit union member business lending cap, HR 2305; Postal Banking - the United States Postal Service should not provide banking services which will be beyond its core competencies, will raise a number of serious regulatory and consumer protection questions, and will present significant competitive issues for private sector entities; Banking regulation and supervision - support the use of formal rulemaking versus informal guidance - agencies should clarify how guidance is treated, as inconsistencies can lead to compliance confusion; ensure that examiners treat regulations and guidance consistently - improve the examination process for financial institutions by passing the Financial Institutions Examination Fairness and Reform Act; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time; Supervisory Committee Audits and Verifications (RIN 3133-AE91) - NCUA should remove the report on examination of internal controls over call reporting alternative audit option - remove the 120-day language in engagement letters to outside, compensated auditors regarding the required written report - support Appendix A to Part 715 alternative audit option - do not include other areas of review in Appendix A - retain Supervisory Committee Guide; Request for Information Regarding Consumer Credit Card Market (Docket No. CFPB-2019-0002) - encourage effective credit card disclosure use, including flexibility to provide required disclosures via mobile banking platforms - support providing fair and transparent credit products and services - support changes to regulations carrying out the Credit Card Accountability Responsibility and Disclosure Act of 2009 as the consumer credit card market evolves - support reporting on the credit card market to ensure practices align with CARD Act - support effective, simple and user friendly credit card disclosures - support allocating resources from Office of Cost-Benefit Analysis toward innovation; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; oppose the Green Amendment (#29) to H.R. 1500 which would reinstate the CFPBs rule on arbitration agreements which Congress voted to disapprove in 2017; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; Property Assessed Clean Energy Loans - support imposing ability-to-repay underwriting requirements for PACE loans - support imposing civil liability on violators of the ATR requirements under section 130 of the Truth In Lending Act - support adopting Truth In Lending - RESPA disclosures for PACE loans; Payday, Vehicle Title, and Certain High-Cost Installment Loans (RIN 3170-AA80) - support rescission of mandatory ability-to-repay (ATR) underwriting requirements - support for delay of compliance date, RIN3170-AA95 - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan (PAL) programs for credit unions - recommend expanding the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales and Computer Employees, (RIN 1235-AA20) - supports the Department of Labors (DOL) proposed adjustments to overtime exemption rules under the Fair Labor Standards Act (FLSA) - urge DOL to consider additional options and guidance to reduce burdens for smaller credit unions - support regulatory flexibility for certain bonuses, incentive payments, and commissions - urge DOL to commit to a future formal assessment of the four-year review of the salary levels, in lieu of automatic reviews or increases; Ginnie Mae, Request for Input on Pooling Eligibility Changes - recommend that Ginnie Mae first allow the VA to complete its own evaluation of VA cash-out refinances, then closely evaluate other changes before removing cash out refinance loans made through the U.S. Department of Veterans Affairs from the Ginnie Mae II Multi-Issuer Program (GIIMIP) - Before excluding VA cash-out refinances, Ginnie Mae should complete further review to determine whether there is more than a correlation between the propensity to rapidly prepay VA loans and the different LTV requirements in the VA program compared to those of the Federal Housing Administration (FHA), Fannie Mae, and Freddie Mac - support a de minimis standard restricting inclusion of cash-out refinances for VA loans in the GII MIP; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws (RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; supports a strong independent NCUA; Consideration of the Financial Services and General Government Appropriations Bill - supports the language in the draft bill to keep funding for the NCUA's Community Development Revolving Loan Fund (CDRLF) at a level of $2 million and to fund the Community Development Financial Institutions (CDFI) Fund at a level of $300 million; NCUA should maintain the current regulation requiring annual review by a federal credit union (FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; A Review of the Appraisal Industry - a formal appraisal should not be required for commercial real estate appraisals; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; support amendment to the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act (COUNTER Act), HR 2514; support amendment to the Corporate Transparency Act of 2019, HR 2513; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support reform bill addressing beneficial ownership requirements; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans (RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases; support the SBAs modernizing the requirements for Certified Development Companies who provide vital 504 program loans; support Title IV of H.R. 3300, the Economic Mobility Act of 2019, which would repeal the 21 percent excise tax imposed on certain not-for-profits for providing certain fringe benefits under the Tax Cuts and Jobs Act (TCJA).; support 2019 NCUA Regulatory Review of 1/3 of NCUA regulations.

Protect the credit union tax exemption; S. 151, the TRACED Act - modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill - reforms should require voice service providers to consult with call originators as they implement the STIR/SHAKEN call authentication framework - require FCC to promulgate rules for the safe harbor available to voice service providers that establish a process to give notice to legitimate callers prior to their calls being blocked and, subsequently, correct any unintended blocking; establish a broad definition of automatic telephone dialing system or autodialer under the TCPA that only includes equipment that uses a random or sequential number generator to store or produce numbers and dial those numbers without human intervention - conduct reforms to help credit unions contact their members with important account information - permit callers to establish a reasonable opt-out method for revoking their consent to be contacted - remove language that goes beyond the scope of addressing the illegal actors who make abusive automated calls and in essence harms businesses and consumers by impeding legitimate calls that consumers actually need or want, HR 946 - support creating reassigned numbers database using existing numbering databases, (CG Docket No. 17-59) - provide a comprehensive safe harbor from TCPA liability for callers who use the database regularly but make a call to a reassigned number due to database errors - urge FCC to seek public comment on draft Declaratory Ruling, Advanced Methods to Target and Eliminate Unlawful Robocalls, (CG Docket No. 17-59, WC Docket No. 17-97); financial literacy - Support HR 275 and the goals and ideals of financial literacy month; Department of Defense - oppose an amendment to provide banks with rent-free leases on military bases under the John S. McCain National Defense Authorization Act - exempt loans to veteran-owned businesses from the credit union member business lending cap, HR 2305; Postal Banking - the United States Postal Service should not provide banking services which will be beyond its core competencies, will raise a number of serious regulatory and consumer protection questions, and will present significant competitive issues for private sector entities; Banking regulation and supervision - support the use of formal rulemaking versus informal guidance - agencies should clarify how guidance is treated, as inconsistencies can lead to compliance confusion; ensure that examiners treat regulations and guidance consistently - improve the examination process for financial institutions by passing the Financial Institutions Examination Fairness and Reform Act; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time; Supervisory Committee Audits and Verifications (RIN 3133-AE91) - NCUA should remove the report on examination of internal controls over call reporting alternative audit option - remove the 120-day language in engagement letters to outside, compensated auditors regarding the required written report - support Appendix A to Part 715 alternative audit option - do not include other areas of review in Appendix A - retain Supervisory Committee Guide; Request for Information Regarding Consumer Credit Card Market (Docket No. CFPB-2019-0002) - encourage effective credit card disclosure use, including flexibility to provide required disclosures via mobile banking platforms - support providing fair and transparent credit products and services - support changes to regulations carrying out the Credit Card Accountability Responsibility and Disclosure Act of 2009 as the consumer credit card market evolves - support reporting on the credit card market to ensure practices align with CARD Act - support effective, simple and user friendly credit card disclosures - support allocating resources from Office of Cost-Benefit Analysis toward innovation; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; oppose the Green Amendment (#29) to H.R. 1500 which would reinstate the CFPBs rule on arbitration agreements which Congress voted to disapprove in 2017; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; Property Assessed Clean Energy Loans - support imposing ability-to-repay underwriting requirements for PACE loans - support imposing civil liability on violators of the ATR requirements under section 130 of the Truth In Lending Act - support adopting Truth In Lending - RESPA disclosures for PACE loans; Payday, Vehicle Title, and Certain High-Cost Installment Loans (RIN 3170-AA80) - support rescission of mandatory ability-to-repay (ATR) underwriting requirements - support for delay of compliance date, RIN3170-AA95 - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan (PAL) programs for credit unions - recommend expanding the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales and Computer Employees, (RIN 1235-AA20) - supports the Department of Labors (DOL) proposed adjustments to overtime exemption rules under the Fair Labor Standards Act (FLSA) - urge DOL to consider additional options and guidance to reduce burdens for smaller credit unions - support regulatory flexibility for certain bonuses, incentive payments, and commissions - urge DOL to commit to a future formal assessment of the four-year review of the salary levels, in lieu of automatic reviews or increases; Ginnie Mae, Request for Input on Pooling Eligibility Changes - recommend that Ginnie Mae first allow the VA to complete its own evaluation of VA cash-out refinances, then closely evaluate other changes before removing cash out refinance loans made through the U.S. Department of Veterans Affairs from the Ginnie Mae II Multi-Issuer Program (GIIMIP) - Before excluding VA cash-out refinances, Ginnie Mae should complete further review to determine whether there is more than a correlation between the propensity to rapidly prepay VA loans and the different LTV requirements in the VA program compared to those of the Federal Housing Administration (FHA), Fannie Mae, and Freddie Mac - support a de minimis standard restricting inclusion of cash-out refinances for VA loans in the GII MIP; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws (RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; supports a strong independent NCUA; Consideration of the Financial Services and General Government Appropriations Bill - supports the language in the draft bill to keep funding for the NCUA's Community Development Revolving Loan Fund (CDRLF) at a level of $2 million and to fund the Community Development Financial Institutions (CDFI) Fund at a level of $300 million; NCUA should maintain the current regulation requiring annual review by a federal credit union (FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; A Review of the Appraisal Industry - a formal appraisal should not be required for commercial real estate appraisals; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; support amendment to the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act (COUNTER Act), HR 2514; support amendment to the Corporate Transparency Act of 2019, HR 2513; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support reform bill addressing beneficial ownership requirements; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans (RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases; support the SBAs modernizing the requirements for Certified Development Companies who provide vital 504 program loans; support Title IV of H.R. 3300, the Economic Mobility Act of 2019, which would repeal the 21 percent excise tax imposed on certain not-for-profits for providing certain fringe benefits under the Tax Cuts and Jobs Act (TCJA).; support 2019 NCUA Regulatory Review of 1/3 of NCUA regualtions;

Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.

Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.

Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.

Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.

Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.

Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.

Protect the credit union tax exemption; S. 151, the TRACED Act - modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill - reforms should require voice service providers to consult with call originators as they implement the STIR/SHAKEN call authentication framework - require FCC to promulgate rules for the safe harbor available to voice service providers that establish a process to give notice to legitimate callers prior to their calls being blocked and, subsequently, correct any unintended blocking; establish a broad definition of automatic telephone dialing system or autodialer under the TCPA that only includes equipment that uses a random or sequential number generator to store or produce numbers and dial those numbers without human intervention - conduct reforms to help credit unions contact their members with important account information - permit callers to establish a reasonable opt-out method for revoking their consent to be contacted - remove language that goes beyond the scope of addressing the illegal actors who make abusive automated calls and in essence harms businesses and consumers by impeding legitimate calls that consumers actually need or want, HR 946 - support creating reassigned numbers database using existing numbering databases, (CG Docket No. 17-59) - provide a comprehensive safe harbor from TCPA liability for callers who use the database regularly but make a call to a reassigned number due to database errors - urge FCC to seek public comment on draft Declaratory Ruling, Advanced Methods to Target and Eliminate Unlawful Robocalls, (CG Docket No. 17-59, WC Docket No. 17-97); financial literacy - Support HR 275 and the goals and ideals of financial literacy month; Department of Defense - oppose an amendment to provide banks with rent-free leases on military bases under the John S. McCain National Defense Authorization Act - exempt loans to veteran-owned businesses from the credit union member business lending cap, HR 2305; Postal Banking - the United States Postal Service should not provide banking services which will be beyond its core competencies, will raise a number of serious regulatory and consumer protection questions, and will present significant competitive issues for private sector entities; Banking regulation and supervision - support the use of formal rulemaking versus informal guidance - agencies should clarify how guidance is treated, as inconsistencies can lead to compliance confusion; ensure that examiners treat regulations and guidance consistently - improve the examination process for financial institutions by passing the Financial Institutions Examination Fairness and Reform Act; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time; Supervisory Committee Audits and Verifications (RIN 3133-AE91) - NCUA should remove the report on examination of internal controls over call reporting alternative audit option - remove the 120-day language in engagement letters to outside, compensated auditors regarding the required written report - support Appendix A to Part 715 alternative audit option - do not include other areas of review in Appendix A - retain Supervisory Committee Guide; Request for Information Regarding Consumer Credit Card Market (Docket No. CFPB-2019-0002) - encourage effective credit card disclosure use, including flexibility to provide required disclosures via mobile banking platforms - support providing fair and transparent credit products and services - support changes to regulations carrying out the Credit Card Accountability Responsibility and Disclosure Act of 2009 as the consumer credit card market evolves - support reporting on the credit card market to ensure practices align with CARD Act - support effective, simple and user friendly credit card disclosures - support allocating resources from Office of Cost-Benefit Analysis toward innovation; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; oppose the Green Amendment (#29) to H.R. 1500 which would reinstate the CFPBs rule on arbitration agreements which Congress voted to disapprove in 2017; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; Property Assessed Clean Energy Loans - support imposing ability-to-repay underwriting requirements for PACE loans - support imposing civil liability on violators of the ATR requirements under section 130 of the Truth In Lending Act - support adopting Truth In Lending - RESPA disclosures for PACE loans; Payday, Vehicle Title, and Certain High-Cost Installment Loans (RIN 3170-AA80) - support rescission of mandatory ability-to-repay (ATR) underwriting requirements - support for delay of compliance date, RIN3170-AA95 - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan (PAL) programs for credit unions - recommend expanding the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales and Computer Employees, (RIN 1235-AA20) - supports the Department of Labors (DOL) proposed adjustments to overtime exemption rules under the Fair Labor Standards Act (FLSA) - urge DOL to consider additional options and guidance to reduce burdens for smaller credit unions - support regulatory flexibility for certain bonuses, incentive payments, and commissions - urge DOL to commit to a future formal assessment of the four-year review of the salary levels, in lieu of automatic reviews or increases; Ginnie Mae, Request for Input on Pooling Eligibility Changes - recommend that Ginnie Mae first allow the VA to complete its own evaluation of VA cash-out refinances, then closely evaluate other changes before removing cash out refinance loans made through the U.S. Department of Veterans Affairs from the Ginnie Mae II Multi-Issuer Program (GIIMIP) - Before excluding VA cash-out refinances, Ginnie Mae should complete further review to determine whether there is more than a correlation between the propensity to rapidly prepay VA loans and the different LTV requirements in the VA program compared to those of the Federal Housing Administration (FHA), Fannie Mae, and Freddie Mac - support a de minimis standard restricting inclusion of cash-out refinances for VA loans in the GII MIP; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws (RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; supports a strong independent NCUA; Consideration of the Financial Services and General Government Appropriations Bill - supports the language in the draft bill to keep funding for the NCUA's Community Development Revolving Loan Fund (CDRLF) at a level of $2 million and to fund the Community Development Financial Institutions (CDFI) Fund at a level of $300 million; NCUA should maintain the current regulation requiring annual review by a federal credit union (FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; A Review of the Appraisal Industry - a formal appraisal should not be required for commercial real estate appraisals; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; support amendment to the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act (COUNTER Act), HR 2514; support amendment to the Corporate Transparency Act of 2019, HR 2513; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support reform bill addressing beneficial ownership requirements; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans (RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases; support the SBAs modernizing the requirements for Certified Development Companies who provide vital 504 program loans; support Title IV of H.R. 3300, the Economic Mobility Act of 2019, which would repeal the 21 percent excise tax imposed on certain not-for-profits for providing certain fringe benefits under the Tax Cuts and Jobs Act (TCJA).; support 2019 NCUA Regulatory Review of 1/3 of NCUA regulations.

Protect the credit union tax exemption; S. 151, the TRACED Act - modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill - reforms should require voice service providers to consult with call originators as they implement the STIR/SHAKEN call authentication framework - require FCC to promulgate rules for the safe harbor available to voice service providers that establish a process to give notice to legitimate callers prior to their calls being blocked and, subsequently, correct any unintended blocking; establish a broad definition of automatic telephone dialing system or autodialer under the TCPA that only includes equipment that uses a random or sequential number generator to store or produce numbers and dial those numbers without human intervention - conduct reforms to help credit unions contact their members with important account information - permit callers to establish a reasonable opt-out method for revoking their consent to be contacted - remove language that goes beyond the scope of addressing the illegal actors who make abusive automated calls and in essence harms businesses and consumers by impeding legitimate calls that consumers actually need or want, HR 946 - support creating reassigned numbers database using existing numbering databases, (CG Docket No. 17-59) - provide a comprehensive safe harbor from TCPA liability for callers who use the database regularly but make a call to a reassigned number due to database errors - urge FCC to seek public comment on draft Declaratory Ruling, Advanced Methods to Target and Eliminate Unlawful Robocalls, (CG Docket No. 17-59, WC Docket No. 17-97); financial literacy - Support HR 275 and the goals and ideals of financial literacy month; Department of Defense - oppose an amendment to provide banks with rent-free leases on military bases under the John S. McCain National Defense Authorization Act - exempt loans to veteran-owned businesses from the credit union member business lending cap, HR 2305; Postal Banking - the United States Postal Service should not provide banking services which will be beyond its core competencies, will raise a number of serious regulatory and consumer protection questions, and will present significant competitive issues for private sector entities; Banking regulation and supervision - support the use of formal rulemaking versus informal guidance - agencies should clarify how guidance is treated, as inconsistencies can lead to compliance confusion; ensure that examiners treat regulations and guidance consistently - improve the examination process for financial institutions by passing the Financial Institutions Examination Fairness and Reform Act; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time; Supervisory Committee Audits and Verifications (RIN 3133-AE91) - NCUA should remove the report on examination of internal controls over call reporting alternative audit option - remove the 120-day language in engagement letters to outside, compensated auditors regarding the required written report - support Appendix A to Part 715 alternative audit option - do not include other areas of review in Appendix A - retain Supervisory Committee Guide; Request for Information Regarding Consumer Credit Card Market (Docket No. CFPB-2019-0002) - encourage effective credit card disclosure use, including flexibility to provide required disclosures via mobile banking platforms - support providing fair and transparent credit products and services - support changes to regulations carrying out the Credit Card Accountability Responsibility and Disclosure Act of 2009 as the consumer credit card market evolves - support reporting on the credit card market to ensure practices align with CARD Act - support effective, simple and user friendly credit card disclosures - support allocating resources from Office of Cost-Benefit Analysis toward innovation; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; oppose the Green Amendment (#29) to H.R. 1500 which would reinstate the CFPBs rule on arbitration agreements which Congress voted to disapprove in 2017; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; Property Assessed Clean Energy Loans - support imposing ability-to-repay underwriting requirements for PACE loans - support imposing civil liability on violators of the ATR requirements under section 130 of the Truth In Lending Act - support adopting Truth In Lending - RESPA disclosures for PACE loans; Payday, Vehicle Title, and Certain High-Cost Installment Loans (RIN 3170-AA80) - support rescission of mandatory ability-to-repay (ATR) underwriting requirements - support for delay of compliance date, RIN3170-AA95 - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan (PAL) programs for credit unions - recommend expanding the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales and Computer Employees, (RIN 1235-AA20) - supports the Department of Labors (DOL) proposed adjustments to overtime exemption rules under the Fair Labor Standards Act (FLSA) - urge DOL to consider additional options and guidance to reduce burdens for smaller credit unions - support regulatory flexibility for certain bonuses, incentive payments, and commissions - urge DOL to commit to a future formal assessment of the four-year review of the salary levels, in lieu of automatic reviews or increases; Ginnie Mae, Request for Input on Pooling Eligibility Changes - recommend that Ginnie Mae first allow the VA to complete its own evaluation of VA cash-out refinances, then closely evaluate other changes before removing cash out refinance loans made through the U.S. Department of Veterans Affairs from the Ginnie Mae II Multi-Issuer Program (GIIMIP) - Before excluding VA cash-out refinances, Ginnie Mae should complete further review to determine whether there is more than a correlation between the propensity to rapidly prepay VA loans and the different LTV requirements in the VA program compared to those of the Federal Housing Administration (FHA), Fannie Mae, and Freddie Mac - support a de minimis standard restricting inclusion of cash-out refinances for VA loans in the GII MIP; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws (RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; supports a strong independent NCUA; Consideration of the Financial Services and General Government Appropriations Bill - supports the language in the draft bill to keep funding for the NCUA's Community Development Revolving Loan Fund (CDRLF) at a level of $2 million and to fund the Community Development Financial Institutions (CDFI) Fund at a level of $300 million; NCUA should maintain the current regulation requiring annual review by a federal credit union (FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; A Review of the Appraisal Industry - a formal appraisal should not be required for commercial real estate appraisals; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; support amendment to the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act (COUNTER Act), HR 2514; support amendment to the Corporate Transparency Act of 2019, HR 2513; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support reform bill addressing beneficial ownership requirements; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans (RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases; support the SBAs modernizing the requirements for Certified Development Companies who provide vital 504 program loans; support Title IV of H.R. 3300, the Economic Mobility Act of 2019, which would repeal the 21 percent excise tax imposed on certain not-for-profits for providing certain fringe benefits under the Tax Cuts and Jobs Act (TCJA).; support 2019 NCUA Regulatory Review of 1/3 of NCUA regualtions;

Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.

Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.

Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.

Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.

Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.

Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.

Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.

Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.

Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.

Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.

Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support legislation such as H.R. 4067, the Financial Inclusion in Banking Act of 2019, which would direct the CFPBs Office of Community Affairs to research how to increase financial inclusion for underserved communities; supports CFPB Director Kathy Kraningers efforts to provide financial institutions with regulatory certainty and targeted relief, while focusing the CFPBs efforts on bad actors; support increased focus on diversity, equity, and inclusion (DEI) within the American economy and the industry; support laws and regulations aimed at detecting and preventing discrimination, as well as the legal mechanisms used to protect fundamental consumer interests; support HUDs objective of updating the Disparate Impact Rule by aligning it more closely with the Supreme Courts decision in Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc., (Inclusive Communities); support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support H.R. 2513, the Corporate Transparency Act of 2019 and the COUNTER Act of 2019; support efforts to modernize the Currency Transaction Report (CTR) threshold by indexing it for inflation; support The Business of Insurance Regulatory Reform Act of 2019; support tech sprints; support regulatory efforts to modernize and streamline supervisory processes; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; Support Interbank real-time gross settlement of faster payments docket No. OP-1670; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; advocate against an expanded consumer compliance examination program; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support implementing regulations that clarify that the requirements of the CCPA and its implementing regulations do not apply to organizations that solely collect GLBA-covered information; support a delay in enforcement of the CCPA; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; H.R. 5315, the Expanding Opportunity for MDIs Act, offered by Representative Joyce Beatty (D-OH) and H.R. 5322, the Ensuring Diversity in Community Banking Act of 2019; support keeping legislative reform of the housing finance system as a priority for the Senate Committee on Banking, Housing Committee on Banking, Housing & Urban Affairs and the House Committee on Financial Services; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; support S. 2563, the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings Act (ILLICIT CASH Act).

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support legislation such as H.R. 4067, the Financial Inclusion in Banking Act of 2019, which would direct the CFPBs Office of Community Affairs to research how to increase financial inclusion for underserved communities; supports CFPB Director Kathy Kraningers efforts to provide financial institutions with regulatory certainty and targeted relief, while focusing the CFPBs efforts on bad actors; support increased focus on diversity, equity, and inclusion (DEI) within the American economy and the industry; support laws and regulations aimed at detecting and preventing discrimination, as well as the legal mechanisms used to protect fundamental consumer interests; support HUDs objective of updating the Disparate Impact Rule by aligning it more closely with the Supreme Courts decision in Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc., (Inclusive Communities); support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support H.R. 2513, the Corporate Transparency Act of 2019 and the COUNTER Act of 2019; support efforts to modernize the Currency Transaction Report (CTR) threshold by indexing it for inflation; support The Business of Insurance Regulatory Reform Act of 2019; support tech sprints; support regulatory efforts to modernize and streamline supervisory processes; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; Support Interbank real-time gross settlement of faster payments docket No. OP-1670; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; advocate against an expanded consumer compliance examination program; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support implementing regulations that clarify that the requirements of the CCPA and its implementing regulations do not apply to organizations that solely collect GLBA-covered information; support a delay in enforcement of the CCPA; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; H.R. 5315, the Expanding Opportunity for MDIs Act, offered by Representative Joyce Beatty (D-OH) and H.R. 5322, the Ensuring Diversity in Community Banking Act of 2019; support keeping legislative reform of the housing finance system as a priority for the Senate Committee on Banking, Housing Committee on Banking, Housing & Urban Affairs and the House Committee on Financial Services; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; support S. 2563, the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings Act (ILLICIT CASH Act).

Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.

Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.

Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support legislation such as H.R. 4067, the Financial Inclusion in Banking Act of 2019, which would direct the CFPBs Office of Community Affairs to research how to increase financial inclusion for underserved communities; supports CFPB Director Kathy Kraningers efforts to provide financial institutions with regulatory certainty and targeted relief, while focusing the CFPBs efforts on bad actors; support increased focus on diversity, equity, and inclusion (DEI) within the American economy and the industry; support laws and regulations aimed at detecting and preventing discrimination, as well as the legal mechanisms used to protect fundamental consumer interests; support HUDs objective of updating the Disparate Impact Rule by aligning it more closely with the Supreme Courts decision in Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc., (Inclusive Communities); support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support H.R. 2513, the Corporate Transparency Act of 2019 and the COUNTER Act of 2019; support efforts to modernize the Currency Transaction Report (CTR) threshold by indexing it for inflation; support The Business of Insurance Regulatory Reform Act of 2019; support tech sprints; support regulatory efforts to modernize and streamline supervisory processes; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; Support Interbank real-time gross settlement of faster payments docket No. OP-1670; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; advocate against an expanded consumer compliance examination program; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support implementing regulations that clarify that the requirements of the CCPA and its implementing regulations do not apply to organizations that solely collect GLBA-covered information; support a delay in enforcement of the CCPA; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; H.R. 5315, the Expanding Opportunity for MDIs Act, offered by Representative Joyce Beatty (D-OH) and H.R. 5322, the Ensuring Diversity in Community Banking Act of 2019; support keeping legislative reform of the housing finance system as a priority for the Senate Committee on Banking, Housing Committee on Banking, Housing & Urban Affairs and the House Committee on Financial Services; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; support S. 2563, the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings Act (ILLICIT CASH Act).

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support legislation such as H.R. 4067, the Financial Inclusion in Banking Act of 2019, which would direct the CFPBs Office of Community Affairs to research how to increase financial inclusion for underserved communities; supports CFPB Director Kathy Kraningers efforts to provide financial institutions with regulatory certainty and targeted relief, while focusing the CFPBs efforts on bad actors; support increased focus on diversity, equity, and inclusion (DEI) within the American economy and the industry; support laws and regulations aimed at detecting and preventing discrimination, as well as the legal mechanisms used to protect fundamental consumer interests; support HUDs objective of updating the Disparate Impact Rule by aligning it more closely with the Supreme Courts decision in Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc., (Inclusive Communities); support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support H.R. 2513, the Corporate Transparency Act of 2019 and the COUNTER Act of 2019; support efforts to modernize the Currency Transaction Report (CTR) threshold by indexing it for inflation; support The Business of Insurance Regulatory Reform Act of 2019; support tech sprints; support regulatory efforts to modernize and streamline supervisory processes; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; Support Interbank real-time gross settlement of faster payments docket No. OP-1670; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; advocate against an expanded consumer compliance examination program; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support implementing regulations that clarify that the requirements of the CCPA and its implementing regulations do not apply to organizations that solely collect GLBA-covered information; support a delay in enforcement of the CCPA; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; H.R. 5315, the Expanding Opportunity for MDIs Act, offered by Representative Joyce Beatty (D-OH) and H.R. 5322, the Ensuring Diversity in Community Banking Act of 2019; support keeping legislative reform of the housing finance system as a priority for the Senate Committee on Banking, Housing Committee on Banking, Housing & Urban Affairs and the House Committee on Financial Services; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; support S. 2563, the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings Act (ILLICIT CASH Act).

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support legislation such as H.R. 4067, the Financial Inclusion in Banking Act of 2019, which would direct the CFPBs Office of Community Affairs to research how to increase financial inclusion for underserved communities; supports CFPB Director Kathy Kraningers efforts to provide financial institutions with regulatory certainty and targeted relief, while focusing the CFPBs efforts on bad actors; support increased focus on diversity, equity, and inclusion (DEI) within the American economy and the industry; support laws and regulations aimed at detecting and preventing discrimination, as well as the legal mechanisms used to protect fundamental consumer interests; support HUDs objective of updating the Disparate Impact Rule by aligning it more closely with the Supreme Courts decision in Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc., (Inclusive Communities); support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support H.R. 2513, the Corporate Transparency Act of 2019 and the COUNTER Act of 2019; support efforts to modernize the Currency Transaction Report (CTR) threshold by indexing it for inflation; support The Business of Insurance Regulatory Reform Act of 2019; support tech sprints; support regulatory efforts to modernize and streamline supervisory processes; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; Support Interbank real-time gross settlement of faster payments docket No. OP-1670; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; advocate against an expanded consumer compliance examination program; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support implementing regulations that clarify that the requirements of the CCPA and its implementing regulations do not apply to organizations that solely collect GLBA-covered information; support a delay in enforcement of the CCPA; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; H.R. 5315, the Expanding Opportunity for MDIs Act, offered by Representative Joyce Beatty (D-OH) and H.R. 5322, the Ensuring Diversity in Community Banking Act of 2019; support keeping legislative reform of the housing finance system as a priority for the Senate Committee on Banking, Housing Committee on Banking, Housing & Urban Affairs and the House Committee on Financial Services; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; support S. 2563, the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings Act (ILLICIT CASH Act).

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support legislation such as H.R. 4067, the Financial Inclusion in Banking Act of 2019, which would direct the CFPBs Office of Community Affairs to research how to increase financial inclusion for underserved communities; supports CFPB Director Kathy Kraningers efforts to provide financial institutions with regulatory certainty and targeted relief, while focusing the CFPBs efforts on bad actors; support increased focus on diversity, equity, and inclusion (DEI) within the American economy and the industry; support laws and regulations aimed at detecting and preventing discrimination, as well as the legal mechanisms used to protect fundamental consumer interests; support HUDs objective of updating the Disparate Impact Rule by aligning it more closely with the Supreme Courts decision in Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc., (Inclusive Communities); support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support H.R. 2513, the Corporate Transparency Act of 2019 and the COUNTER Act of 2019; support efforts to modernize the Currency Transaction Report (CTR) threshold by indexing it for inflation; support The Business of Insurance Regulatory Reform Act of 2019; support tech sprints; support regulatory efforts to modernize and streamline supervisory processes; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; Support Interbank real-time gross settlement of faster payments docket No. OP-1670; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; advocate against an expanded consumer compliance examination program; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support implementing regulations that clarify that the requirements of the CCPA and its implementing regulations do not apply to organizations that solely collect GLBA-covered information; support a delay in enforcement of the CCPA; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; H.R. 5315, the Expanding Opportunity for MDIs Act, offered by Representative Joyce Beatty (D-OH) and H.R. 5322, the Ensuring Diversity in Community Banking Act of 2019; support keeping legislative reform of the housing finance system as a priority for the Senate Committee on Banking, Housing Committee on Banking, Housing & Urban Affairs and the House Committee on Financial Services; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; support S. 2563, the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings Act (ILLICIT CASH Act).

Protect the credit union tax exemption; S. 151, the TRACED Act - modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill - reforms should require voice service providers to consult with call originators as they implement the STIR/SHAKEN call authentication framework - require FCC to promulgate rules for the safe harbor available to voice service providers that establish a process to give notice to legitimate callers prior to their calls being blocked and, subsequently, correct any unintended blocking; establish a broad definition of automatic telephone dialing system or autodialer under the TCPA that only includes equipment that uses a random or sequential number generator to store or produce numbers and dial those numbers without human intervention - conduct reforms to help credit unions contact their members with important account information - permit callers to establish a reasonable opt-out method for revoking their consent to be contacted - remove language that goes beyond the scope of addressing the illegal actors who make abusive automated calls and in essence harms businesses and consumers by impeding legitimate calls that consumers actually need or want, HR 946 - support creating reassigned numbers database using existing numbering databases, (CG Docket No. 17-59) - provide a comprehensive safe harbor from TCPA liability for callers who use the database regularly but make a call to a reassigned number due to database errors - urge FCC to seek public comment on draft Declaratory Ruling, Advanced Methods to Target and Eliminate Unlawful Robocalls, (CG Docket No. 17-59, WC Docket No. 17-97); financial literacy - Support HR 275 and the goals and ideals of financial literacy month; Department of Defense - oppose an amendment to provide banks with rent-free leases on military bases under the John S. McCain National Defense Authorization Act - exempt loans to veteran-owned businesses from the credit union member business lending cap, HR 2305; Postal Banking - the United States Postal Service should not provide banking services which will be beyond its core competencies, will raise a number of serious regulatory and consumer protection questions, and will present significant competitive issues for private sector entities; Banking regulation and supervision - support the use of formal rulemaking versus informal guidance - agencies should clarify how guidance is treated, as inconsistencies can lead to compliance confusion; ensure that examiners treat regulations and guidance consistently - improve the examination process for financial institutions by passing the Financial Institutions Examination Fairness and Reform Act; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time; Supervisory Committee Audits and Verifications (RIN 3133-AE91) - NCUA should remove the report on examination of internal controls over call reporting alternative audit option - remove the 120-day language in engagement letters to outside, compensated auditors regarding the required written report - support Appendix A to Part 715 alternative audit option - do not include other areas of review in Appendix A - retain Supervisory Committee Guide; Request for Information Regarding Consumer Credit Card Market (Docket No. CFPB-2019-0002) - encourage effective credit card disclosure use, including flexibility to provide required disclosures via mobile banking platforms - support providing fair and transparent credit products and services - support changes to regulations carrying out the Credit Card Accountability Responsibility and Disclosure Act of 2009 as the consumer credit card market evolves - support reporting on the credit card market to ensure practices align with CARD Act - support effective, simple and user friendly credit card disclosures - support allocating resources from Office of Cost-Benefit Analysis toward innovation; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; oppose the Green Amendment (#29) to H.R. 1500 which would reinstate the CFPBs rule on arbitration agreements which Congress voted to disapprove in 2017; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; Property Assessed Clean Energy Loans - support imposing ability-to-repay underwriting requirements for PACE loans - support imposing civil liability on violators of the ATR requirements under section 130 of the Truth In Lending Act - support adopting Truth In Lending - RESPA disclosures for PACE loans; Payday, Vehicle Title, and Certain High-Cost Installment Loans (RIN 3170-AA80) - support rescission of mandatory ability-to-repay (ATR) underwriting requirements - support for delay of compliance date, RIN3170-AA95 - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan (PAL) programs for credit unions - recommend expanding the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales and Computer Employees, (RIN 1235-AA20) - supports the Department of Labors (DOL) proposed adjustments to overtime exemption rules under the Fair Labor Standards Act (FLSA) - urge DOL to consider additional options and guidance to reduce burdens for smaller credit unions - support regulatory flexibility for certain bonuses, incentive payments, and commissions - urge DOL to commit to a future formal assessment of the four-year review of the salary levels, in lieu of automatic reviews or increases; Ginnie Mae, Request for Input on Pooling Eligibility Changes - recommend that Ginnie Mae first allow the VA to complete its own evaluation of VA cash-out refinances, then closely evaluate other changes before removing cash out refinance loans made through the U.S. Department of Veterans Affairs from the Ginnie Mae II Multi-Issuer Program (GIIMIP) - Before excluding VA cash-out refinances, Ginnie Mae should complete further review to determine whether there is more than a correlation between the propensity to rapidly prepay VA loans and the different LTV requirements in the VA program compared to those of the Federal Housing Administration (FHA), Fannie Mae, and Freddie Mac - support a de minimis standard restricting inclusion of cash-out refinances for VA loans in the GII MIP; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws (RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; supports a strong independent NCUA; Consideration of the Financial Services and General Government Appropriations Bill - supports the language in the draft bill to keep funding for the NCUA's Community Development Revolving Loan Fund (CDRLF) at a level of $2 million and to fund the Community Development Financial Institutions (CDFI) Fund at a level of $300 million; NCUA should maintain the current regulation requiring annual review by a federal credit union (FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; A Review of the Appraisal Industry - a formal appraisal should not be required for commercial real estate appraisals; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; support amendment to the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act (COUNTER Act), HR 2514; support amendment to the Corporate Transparency Act of 2019, HR 2513; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support reform bill addressing beneficial ownership requirements; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans (RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases; support the SBAs modernizing the requirements for Certified Development Companies who provide vital 504 program loans; support Title IV of H.R. 3300, the Economic Mobility Act of 2019, which would repeal the 21 percent excise tax imposed on certain not-for-profits for providing certain fringe benefits under the Tax Cuts and Jobs Act (TCJA).; support 2019 NCUA Regulatory Review of 1/3 of NCUA regualtions;

Protect the credit union tax exemption; S. 151, the TRACED Act - modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill - reforms should require voice service providers to consult with call originators as they implement the STIR/SHAKEN call authentication framework - require FCC to promulgate rules for the safe harbor available to voice service providers that establish a process to give notice to legitimate callers prior to their calls being blocked and, subsequently, correct any unintended blocking; establish a broad definition of automatic telephone dialing system or autodialer under the TCPA that only includes equipment that uses a random or sequential number generator to store or produce numbers and dial those numbers without human intervention - conduct reforms to help credit unions contact their members with important account information - permit callers to establish a reasonable opt-out method for revoking their consent to be contacted - remove language that goes beyond the scope of addressing the illegal actors who make abusive automated calls and in essence harms businesses and consumers by impeding legitimate calls that consumers actually need or want, HR 946 - support creating reassigned numbers database using existing numbering databases, (CG Docket No. 17-59) - provide a comprehensive safe harbor from TCPA liability for callers who use the database regularly but make a call to a reassigned number due to database errors - urge FCC to seek public comment on draft Declaratory Ruling, Advanced Methods to Target and Eliminate Unlawful Robocalls, (CG Docket No. 17-59, WC Docket No. 17-97); financial literacy - Support HR 275 and the goals and ideals of financial literacy month; Department of Defense - oppose an amendment to provide banks with rent-free leases on military bases under the John S. McCain National Defense Authorization Act - exempt loans to veteran-owned businesses from the credit union member business lending cap, HR 2305; Postal Banking - the United States Postal Service should not provide banking services which will be beyond its core competencies, will raise a number of serious regulatory and consumer protection questions, and will present significant competitive issues for private sector entities; Banking regulation and supervision - support the use of formal rulemaking versus informal guidance - agencies should clarify how guidance is treated, as inconsistencies can lead to compliance confusion; ensure that examiners treat regulations and guidance consistently - improve the examination process for financial institutions by passing the Financial Institutions Examination Fairness and Reform Act; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time; Supervisory Committee Audits and Verifications (RIN 3133-AE91) - NCUA should remove the report on examination of internal controls over call reporting alternative audit option - remove the 120-day language in engagement letters to outside, compensated auditors regarding the required written report - support Appendix A to Part 715 alternative audit option - do not include other areas of review in Appendix A - retain Supervisory Committee Guide; Request for Information Regarding Consumer Credit Card Market (Docket No. CFPB-2019-0002) - encourage effective credit card disclosure use, including flexibility to provide required disclosures via mobile banking platforms - support providing fair and transparent credit products and services - support changes to regulations carrying out the Credit Card Accountability Responsibility and Disclosure Act of 2009 as the consumer credit card market evolves - support reporting on the credit card market to ensure practices align with CARD Act - support effective, simple and user friendly credit card disclosures - support allocating resources from Office of Cost-Benefit Analysis toward innovation; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; oppose the Green Amendment (#29) to H.R. 1500 which would reinstate the CFPBs rule on arbitration agreements which Congress voted to disapprove in 2017; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; Property Assessed Clean Energy Loans - support imposing ability-to-repay underwriting requirements for PACE loans - support imposing civil liability on violators of the ATR requirements under section 130 of the Truth In Lending Act - support adopting Truth In Lending - RESPA disclosures for PACE loans; Payday, Vehicle Title, and Certain High-Cost Installment Loans (RIN 3170-AA80) - support rescission of mandatory ability-to-repay (ATR) underwriting requirements - support for delay of compliance date, RIN3170-AA95 - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan (PAL) programs for credit unions - recommend expanding the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales and Computer Employees, (RIN 1235-AA20) - supports the Department of Labors (DOL) proposed adjustments to overtime exemption rules under the Fair Labor Standards Act (FLSA) - urge DOL to consider additional options and guidance to reduce burdens for smaller credit unions - support regulatory flexibility for certain bonuses, incentive payments, and commissions - urge DOL to commit to a future formal assessment of the four-year review of the salary levels, in lieu of automatic reviews or increases; Ginnie Mae, Request for Input on Pooling Eligibility Changes - recommend that Ginnie Mae first allow the VA to complete its own evaluation of VA cash-out refinances, then closely evaluate other changes before removing cash out refinance loans made through the U.S. Department of Veterans Affairs from the Ginnie Mae II Multi-Issuer Program (GIIMIP) - Before excluding VA cash-out refinances, Ginnie Mae should complete further review to determine whether there is more than a correlation between the propensity to rapidly prepay VA loans and the different LTV requirements in the VA program compared to those of the Federal Housing Administration (FHA), Fannie Mae, and Freddie Mac - support a de minimis standard restricting inclusion of cash-out refinances for VA loans in the GII MIP; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws (RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; supports a strong independent NCUA; Consideration of the Financial Services and General Government Appropriations Bill - supports the language in the draft bill to keep funding for the NCUA's Community Development Revolving Loan Fund (CDRLF) at a level of $2 million and to fund the Community Development Financial Institutions (CDFI) Fund at a level of $300 million; NCUA should maintain the current regulation requiring annual review by a federal credit union (FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; A Review of the Appraisal Industry - a formal appraisal should not be required for commercial real estate appraisals; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; support amendment to the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act (COUNTER Act), HR 2514; support amendment to the Corporate Transparency Act of 2019, HR 2513; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support reform bill addressing beneficial ownership requirements; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans (RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases; support the SBAs modernizing the requirements for Certified Development Companies who provide vital 504 program loans; support Title IV of H.R. 3300, the Economic Mobility Act of 2019, which would repeal the 21 percent excise tax imposed on certain not-for-profits for providing certain fringe benefits under the Tax Cuts and Jobs Act (TCJA).; support 2019 NCUA Regulatory Review of 1/3 of NCUA regulations.

Protect the credit union tax exemption; S. 151, the TRACED Act - modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill - reforms should require voice service providers to consult with call originators as they implement the STIR/SHAKEN call authentication framework - require FCC to promulgate rules for the safe harbor available to voice service providers that establish a process to give notice to legitimate callers prior to their calls being blocked and, subsequently, correct any unintended blocking; establish a broad definition of automatic telephone dialing system or autodialer under the TCPA that only includes equipment that uses a random or sequential number generator to store or produce numbers and dial those numbers without human intervention - conduct reforms to help credit unions contact their members with important account information - permit callers to establish a reasonable opt-out method for revoking their consent to be contacted - remove language that goes beyond the scope of addressing the illegal actors who make abusive automated calls and in essence harms businesses and consumers by impeding legitimate calls that consumers actually need or want, HR 946 - support creating reassigned numbers database using existing numbering databases, (CG Docket No. 17-59) - provide a comprehensive safe harbor from TCPA liability for callers who use the database regularly but make a call to a reassigned number due to database errors - urge FCC to seek public comment on draft Declaratory Ruling, Advanced Methods to Target and Eliminate Unlawful Robocalls, (CG Docket No. 17-59, WC Docket No. 17-97); financial literacy - Support HR 275 and the goals and ideals of financial literacy month; Department of Defense - oppose an amendment to provide banks with rent-free leases on military bases under the John S. McCain National Defense Authorization Act - exempt loans to veteran-owned businesses from the credit union member business lending cap, HR 2305; Postal Banking - the United States Postal Service should not provide banking services which will be beyond its core competencies, will raise a number of serious regulatory and consumer protection questions, and will present significant competitive issues for private sector entities; Banking regulation and supervision - support the use of formal rulemaking versus informal guidance - agencies should clarify how guidance is treated, as inconsistencies can lead to compliance confusion; ensure that examiners treat regulations and guidance consistently - improve the examination process for financial institutions by passing the Financial Institutions Examination Fairness and Reform Act; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time; Supervisory Committee Audits and Verifications (RIN 3133-AE91) - NCUA should remove the report on examination of internal controls over call reporting alternative audit option - remove the 120-day language in engagement letters to outside, compensated auditors regarding the required written report - support Appendix A to Part 715 alternative audit option - do not include other areas of review in Appendix A - retain Supervisory Committee Guide; Request for Information Regarding Consumer Credit Card Market (Docket No. CFPB-2019-0002) - encourage effective credit card disclosure use, including flexibility to provide required disclosures via mobile banking platforms - support providing fair and transparent credit products and services - support changes to regulations carrying out the Credit Card Accountability Responsibility and Disclosure Act of 2009 as the consumer credit card market evolves - support reporting on the credit card market to ensure practices align with CARD Act - support effective, simple and user friendly credit card disclosures - support allocating resources from Office of Cost-Benefit Analysis toward innovation; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; oppose the Green Amendment (#29) to H.R. 1500 which would reinstate the CFPBs rule on arbitration agreements which Congress voted to disapprove in 2017; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; Property Assessed Clean Energy Loans - support imposing ability-to-repay underwriting requirements for PACE loans - support imposing civil liability on violators of the ATR requirements under section 130 of the Truth In Lending Act - support adopting Truth In Lending - RESPA disclosures for PACE loans; Payday, Vehicle Title, and Certain High-Cost Installment Loans (RIN 3170-AA80) - support rescission of mandatory ability-to-repay (ATR) underwriting requirements - support for delay of compliance date, RIN3170-AA95 - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan (PAL) programs for credit unions - recommend expanding the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales and Computer Employees, (RIN 1235-AA20) - supports the Department of Labors (DOL) proposed adjustments to overtime exemption rules under the Fair Labor Standards Act (FLSA) - urge DOL to consider additional options and guidance to reduce burdens for smaller credit unions - support regulatory flexibility for certain bonuses, incentive payments, and commissions - urge DOL to commit to a future formal assessment of the four-year review of the salary levels, in lieu of automatic reviews or increases; Ginnie Mae, Request for Input on Pooling Eligibility Changes - recommend that Ginnie Mae first allow the VA to complete its own evaluation of VA cash-out refinances, then closely evaluate other changes before removing cash out refinance loans made through the U.S. Department of Veterans Affairs from the Ginnie Mae II Multi-Issuer Program (GIIMIP) - Before excluding VA cash-out refinances, Ginnie Mae should complete further review to determine whether there is more than a correlation between the propensity to rapidly prepay VA loans and the different LTV requirements in the VA program compared to those of the Federal Housing Administration (FHA), Fannie Mae, and Freddie Mac - support a de minimis standard restricting inclusion of cash-out refinances for VA loans in the GII MIP; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws (RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; supports a strong independent NCUA; Consideration of the Financial Services and General Government Appropriations Bill - supports the language in the draft bill to keep funding for the NCUA's Community Development Revolving Loan Fund (CDRLF) at a level of $2 million and to fund the Community Development Financial Institutions (CDFI) Fund at a level of $300 million; NCUA should maintain the current regulation requiring annual review by a federal credit union (FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; A Review of the Appraisal Industry - a formal appraisal should not be required for commercial real estate appraisals; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; support amendment to the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act (COUNTER Act), HR 2514; support amendment to the Corporate Transparency Act of 2019, HR 2513; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support reform bill addressing beneficial ownership requirements; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans (RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases; support the SBAs modernizing the requirements for Certified Development Companies who provide vital 504 program loans; support Title IV of H.R. 3300, the Economic Mobility Act of 2019, which would repeal the 21 percent excise tax imposed on certain not-for-profits for providing certain fringe benefits under the Tax Cuts and Jobs Act (TCJA).; support 2019 NCUA Regulatory Review of 1/3 of NCUA regulations.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support legislation such as H.R. 4067, the Financial Inclusion in Banking Act of 2019, which would direct the CFPBs Office of Community Affairs to research how to increase financial inclusion for underserved communities; supports CFPB Director Kathy Kraningers efforts to provide financial institutions with regulatory certainty and targeted relief, while focusing the CFPBs efforts on bad actors; support increased focus on diversity, equity, and inclusion (DEI) within the American economy and the industry; support laws and regulations aimed at detecting and preventing discrimination, as well as the legal mechanisms used to protect fundamental consumer interests; support HUDs objective of updating the Disparate Impact Rule by aligning it more closely with the Supreme Courts decision in Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc., (Inclusive Communities); support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support H.R. 2513, the Corporate Transparency Act of 2019 and the COUNTER Act of 2019; support efforts to modernize the Currency Transaction Report (CTR) threshold by indexing it for inflation; support The Business of Insurance Regulatory Reform Act of 2019; support tech sprints; support regulatory efforts to modernize and streamline supervisory processes; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; Support Interbank real-time gross settlement of faster payments docket No. OP-1670; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; advocate against an expanded consumer compliance examination program; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support implementing regulations that clarify that the requirements of the CCPA and its implementing regulations do not apply to organizations that solely collect GLBA-covered information; support a delay in enforcement of the CCPA; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; H.R. 5315, the Expanding Opportunity for MDIs Act, offered by Representative Joyce Beatty (D-OH) and H.R. 5322, the Ensuring Diversity in Community Banking Act of 2019; support keeping legislative reform of the housing finance system as a priority for the Senate Committee on Banking, Housing Committee on Banking, Housing & Urban Affairs and the House Committee on Financial Services; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; support S. 2563, the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings Act (ILLICIT CASH Act).

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support legislation such as H.R. 4067, the Financial Inclusion in Banking Act of 2019, which would direct the CFPBs Office of Community Affairs to research how to increase financial inclusion for underserved communities; supports CFPB Director Kathy Kraningers efforts to provide financial institutions with regulatory certainty and targeted relief, while focusing the CFPBs efforts on bad actors; support increased focus on diversity, equity, and inclusion (DEI) within the American economy and the industry; support laws and regulations aimed at detecting and preventing discrimination, as well as the legal mechanisms used to protect fundamental consumer interests; support HUDs objective of updating the Disparate Impact Rule by aligning it more closely with the Supreme Courts decision in Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc., (Inclusive Communities); support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support H.R. 2513, the Corporate Transparency Act of 2019 and the COUNTER Act of 2019; support efforts to modernize the Currency Transaction Report (CTR) threshold by indexing it for inflation; support The Business of Insurance Regulatory Reform Act of 2019; support tech sprints; support regulatory efforts to modernize and streamline supervisory processes; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; Support Interbank real-time gross settlement of faster payments docket No. OP-1670; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; advocate against an expanded consumer compliance examination program; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support implementing regulations that clarify that the requirements of the CCPA and its implementing regulations do not apply to organizations that solely collect GLBA-covered information; support a delay in enforcement of the CCPA; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; H.R. 5315, the Expanding Opportunity for MDIs Act, offered by Representative Joyce Beatty (D-OH) and H.R. 5322, the Ensuring Diversity in Community Banking Act of 2019; support keeping legislative reform of the housing finance system as a priority for the Senate Committee on Banking, Housing Committee on Banking, Housing & Urban Affairs and the House Committee on Financial Services; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; support S. 2563, the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings Act (ILLICIT CASH Act).

Protect the credit union tax exemption; S. 151, the TRACED Act - modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill - reforms should require voice service providers to consult with call originators as they implement the STIR/SHAKEN call authentication framework - require FCC to promulgate rules for the safe harbor available to voice service providers that establish a process to give notice to legitimate callers prior to their calls being blocked and, subsequently, correct any unintended blocking; establish a broad definition of automatic telephone dialing system or autodialer under the TCPA that only includes equipment that uses a random or sequential number generator to store or produce numbers and dial those numbers without human intervention - conduct reforms to help credit unions contact their members with important account information - permit callers to establish a reasonable opt-out method for revoking their consent to be contacted - remove language that goes beyond the scope of addressing the illegal actors who make abusive automated calls and in essence harms businesses and consumers by impeding legitimate calls that consumers actually need or want, HR 946 - support creating reassigned numbers database using existing numbering databases, (CG Docket No. 17-59) - provide a comprehensive safe harbor from TCPA liability for callers who use the database regularly but make a call to a reassigned number due to database errors - urge FCC to seek public comment on draft Declaratory Ruling, Advanced Methods to Target and Eliminate Unlawful Robocalls, (CG Docket No. 17-59, WC Docket No. 17-97); financial literacy - Support HR 275 and the goals and ideals of financial literacy month; Department of Defense - oppose an amendment to provide banks with rent-free leases on military bases under the John S. McCain National Defense Authorization Act - exempt loans to veteran-owned businesses from the credit union member business lending cap, HR 2305; Postal Banking - the United States Postal Service should not provide banking services which will be beyond its core competencies, will raise a number of serious regulatory and consumer protection questions, and will present significant competitive issues for private sector entities; Banking regulation and supervision - support the use of formal rulemaking versus informal guidance - agencies should clarify how guidance is treated, as inconsistencies can lead to compliance confusion; ensure that examiners treat regulations and guidance consistently - improve the examination process for financial institutions by passing the Financial Institutions Examination Fairness and Reform Act; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time; Supervisory Committee Audits and Verifications (RIN 3133-AE91) - NCUA should remove the report on examination of internal controls over call reporting alternative audit option - remove the 120-day language in engagement letters to outside, compensated auditors regarding the required written report - support Appendix A to Part 715 alternative audit option - do not include other areas of review in Appendix A - retain Supervisory Committee Guide; Request for Information Regarding Consumer Credit Card Market (Docket No. CFPB-2019-0002) - encourage effective credit card disclosure use, including flexibility to provide required disclosures via mobile banking platforms - support providing fair and transparent credit products and services - support changes to regulations carrying out the Credit Card Accountability Responsibility and Disclosure Act of 2009 as the consumer credit card market evolves - support reporting on the credit card market to ensure practices align with CARD Act - support effective, simple and user friendly credit card disclosures - support allocating resources from Office of Cost-Benefit Analysis toward innovation; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; oppose the Green Amendment (#29) to H.R. 1500 which would reinstate the CFPBs rule on arbitration agreements which Congress voted to disapprove in 2017; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; Property Assessed Clean Energy Loans - support imposing ability-to-repay underwriting requirements for PACE loans - support imposing civil liability on violators of the ATR requirements under section 130 of the Truth In Lending Act - support adopting Truth In Lending - RESPA disclosures for PACE loans; Payday, Vehicle Title, and Certain High-Cost Installment Loans (RIN 3170-AA80) - support rescission of mandatory ability-to-repay (ATR) underwriting requirements - support for delay of compliance date, RIN3170-AA95 - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan (PAL) programs for credit unions - recommend expanding the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales and Computer Employees, (RIN 1235-AA20) - supports the Department of Labors (DOL) proposed adjustments to overtime exemption rules under the Fair Labor Standards Act (FLSA) - urge DOL to consider additional options and guidance to reduce burdens for smaller credit unions - support regulatory flexibility for certain bonuses, incentive payments, and commissions - urge DOL to commit to a future formal assessment of the four-year review of the salary levels, in lieu of automatic reviews or increases; Ginnie Mae, Request for Input on Pooling Eligibility Changes - recommend that Ginnie Mae first allow the VA to complete its own evaluation of VA cash-out refinances, then closely evaluate other changes before removing cash out refinance loans made through the U.S. Department of Veterans Affairs from the Ginnie Mae II Multi-Issuer Program (GIIMIP) - Before excluding VA cash-out refinances, Ginnie Mae should complete further review to determine whether there is more than a correlation between the propensity to rapidly prepay VA loans and the different LTV requirements in the VA program compared to those of the Federal Housing Administration (FHA), Fannie Mae, and Freddie Mac - support a de minimis standard restricting inclusion of cash-out refinances for VA loans in the GII MIP; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws (RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; supports a strong independent NCUA; Consideration of the Financial Services and General Government Appropriations Bill - supports the language in the draft bill to keep funding for the NCUA's Community Development Revolving Loan Fund (CDRLF) at a level of $2 million and to fund the Community Development Financial Institutions (CDFI) Fund at a level of $300 million; NCUA should maintain the current regulation requiring annual review by a federal credit union (FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; A Review of the Appraisal Industry - a formal appraisal should not be required for commercial real estate appraisals; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; support amendment to the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act (COUNTER Act), HR 2514; support amendment to the Corporate Transparency Act of 2019, HR 2513; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support reform bill addressing beneficial ownership requirements; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans (RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases; support the SBAs modernizing the requirements for Certified Development Companies who provide vital 504 program loans; support Title IV of H.R. 3300, the Economic Mobility Act of 2019, which would repeal the 21 percent excise tax imposed on certain not-for-profits for providing certain fringe benefits under the Tax Cuts and Jobs Act (TCJA).; support 2019 NCUA Regulatory Review of 1/3 of NCUA regualtions;

Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.

Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support legislation such as H.R. 4067, the Financial Inclusion in Banking Act of 2019, which would direct the CFPBs Office of Community Affairs to research how to increase financial inclusion for underserved communities; supports CFPB Director Kathy Kraningers efforts to provide financial institutions with regulatory certainty and targeted relief, while focusing the CFPBs efforts on bad actors; support increased focus on diversity, equity, and inclusion (DEI) within the American economy and the industry; support laws and regulations aimed at detecting and preventing discrimination, as well as the legal mechanisms used to protect fundamental consumer interests; support HUDs objective of updating the Disparate Impact Rule by aligning it more closely with the Supreme Courts decision in Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc., (Inclusive Communities); support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support H.R. 2513, the Corporate Transparency Act of 2019 and the COUNTER Act of 2019; support efforts to modernize the Currency Transaction Report (CTR) threshold by indexing it for inflation; support The Business of Insurance Regulatory Reform Act of 2019; support tech sprints; support regulatory efforts to modernize and streamline supervisory processes; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; Support Interbank real-time gross settlement of faster payments docket No. OP-1670; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; advocate against an expanded consumer compliance examination program; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support implementing regulations that clarify that the requirements of the CCPA and its implementing regulations do not apply to organizations that solely collect GLBA-covered information; support a delay in enforcement of the CCPA; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; H.R. 5315, the Expanding Opportunity for MDIs Act, offered by Representative Joyce Beatty (D-OH) and H.R. 5322, the Ensuring Diversity in Community Banking Act of 2019; support keeping legislative reform of the housing finance system as a priority for the Senate Committee on Banking, Housing Committee on Banking, Housing & Urban Affairs and the House Committee on Financial Services; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; support S. 2563, the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings Act (ILLICIT CASH Act).

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support legislation such as H.R. 4067, the Financial Inclusion in Banking Act of 2019, which would direct the CFPBs Office of Community Affairs to research how to increase financial inclusion for underserved communities; supports CFPB Director Kathy Kraningers efforts to provide financial institutions with regulatory certainty and targeted relief, while focusing the CFPBs efforts on bad actors; support increased focus on diversity, equity, and inclusion (DEI) within the American economy and the industry; support laws and regulations aimed at detecting and preventing discrimination, as well as the legal mechanisms used to protect fundamental consumer interests; support HUDs objective of updating the Disparate Impact Rule by aligning it more closely with the Supreme Courts decision in Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc., (Inclusive Communities); support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support H.R. 2513, the Corporate Transparency Act of 2019 and the COUNTER Act of 2019; support efforts to modernize the Currency Transaction Report (CTR) threshold by indexing it for inflation; support The Business of Insurance Regulatory Reform Act of 2019; support tech sprints; support regulatory efforts to modernize and streamline supervisory processes; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; Support Interbank real-time gross settlement of faster payments docket No. OP-1670; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; advocate against an expanded consumer compliance examination program; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support implementing regulations that clarify that the requirements of the CCPA and its implementing regulations do not apply to organizations that solely collect GLBA-covered information; support a delay in enforcement of the CCPA; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; H.R. 5315, the Expanding Opportunity for MDIs Act, offered by Representative Joyce Beatty (D-OH) and H.R. 5322, the Ensuring Diversity in Community Banking Act of 2019; support keeping legislative reform of the housing finance system as a priority for the Senate Committee on Banking, Housing Committee on Banking, Housing & Urban Affairs and the House Committee on Financial Services; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; support S. 2563, the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings Act (ILLICIT CASH Act).