mr DAVID SCHROEDER

Legislation and Regulation - H.R. 6955 the Main Street Capital Access Act (All Sections) regarding regulatory fairness, transparency and right-sizing; promoting healthy, growing, and competitive banking industry; and improving access to funding and capital for small to mid-sized banks (House) S. 5526 the Agricultural Act of 2026 specifically regarding an amendment offered by Senators Justice and Welch concerning allowing Farm Credit to expand the definition of rural communities in which they can make home loans (Senate) H.R. 10325 (All Sections) a bill to increase the mandatory contribution Federal Home Loan Banks make to Affordable Housing Programs (AHPs) All Sections (House) H.R. 6644 and S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act specifically including the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) and regarding final passage (House and Senate) H.R. 3633 the CLARITY Act (Section 404) specifically regarding stablecoin yield or rewards or incentives and the potential to disintermediate community bank deposits (Senate) Letters - Letter to the Federal Reserve regarding - Proposed Revisions to the Federal Reserve Policy on Payment System Risk and the Guidance for Account Services Requests (AKA Skinny master accounts)- Docket No. OP-1878 (Federal Reserve) Action Alerts - Action Alert - Urge the Federal Reserve to Protect the Payments System regarding access to the payments system for limited service or Skinny master accounts (Federal Reserve) Action Alert - Urge Your U.S. House Member to Support the Main Street Capital Access Act (H.R. 6955) (House) specifically regarding regulatory fairness, transparency and right-sizing; promoting healthy, growing, and competitive banking industry; and improving access to funding and capital for small to mid-sized banks (House) Action Alert - Urge Illinois Senators to Protect Community Bank Deposits in the CLARITY Act regarding disintermediation of community bank deposits from stablecoin issuers and exchanges from paying interest or rewards on stablecoin deposits (Senate) Miscellaneous - Check Fraud - Status of the results of the June of 2025 joint regulator Request For Information (RFI) on payments/check fraud (Fed, OCC and FDIC) AI - Awareness of the various issues surrounding its use (House)

Legislation and Regulation - S. 5526 the Agricultural Act of 2026 specifically regarding an amendment offered by Senators Justice and Welch concerning allowing Farm Credit to expand the definition of rural communities in which they can make home loans (Senate) H.R. 6644 and S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act including the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) and regarding final passage (House and Senate) Letters - None Action Alerts - Action Alert - Urge Illinois Senators to Protect Community Bank Deposits in the CLARITY Act regarding disintermediation of community bank deposits from stablecoin issuers and exchanges from paying interest or rewards on stablecoin deposits (Senate) Miscellaneous - Check Fraud - Status of the results of the June of 2025 joint regulator Request For Information (RFI) on payments/check fraud (Fed, OCC and FDIC)

Legislation and Regulation - H.R. 6644 and S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act including the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) and regarding final passage (House and Senate) H.R. 10325 (All Sections) a bill to increase the mandatory contribution Federal Home Loan Banks make to Affordable Housing Programs (AHPs) All Sections (House) Letters - None Action Alerts - None Miscellaneous - None

Legislation and Regulation - H.R. 6644 and S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act including the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) and regarding final passage (House and Senate) Action Alerts - Action Alert - Urge Illinois Senators to Protect Community Bank Deposits in the CLARITY Act regarding disintermediation of community bank deposits from stablecoin issuers and exchanges from paying interest or rewards on stablecoin deposits (Senate) Letters - None Miscellaneous - Check Fraud - Status of the results of the June of 2025 joint regulator Request For Information (RFI) on payments/check fraud (Fed, OCC and FDIC)

Legislation and Regulation - H.R. 6955 the Main Street Capital Access Act (All Sections) regarding regulatory fairness, transparency and right-sizing; promoting healthy, growing, and competitive banking industry; and improving access to funding and capital for small to mid-sized banks (House) S. 5526 the Agricultural Act of 2026 specifically regarding an amendment offered by Senators Justice and Welch concerning allowing Farm Credit to expand the definition of rural communities in which they can make home loans (Senate) H.R. 10325 (All Sections) a bill to increase the mandatory contribution Federal Home Loan Banks make to Affordable Housing Programs (AHPs) All Sections (House) H.R. 6644 and S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act specifically including the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) and regarding final passage (House and Senate) H.R. 3633 the CLARITY Act (Section 404) specifically regarding stablecoin yield or rewards or incentives and the potential to disintermediate community bank deposits (Senate) Letters - Letter to the Federal Reserve regarding - Proposed Revisions to the Federal Reserve Policy on Payment System Risk and the Guidance for Account Services Requests (AKA Skinny master accounts)- Docket No. OP-1878 (Federal Reserve) Action Alerts - Action Alert - Urge the Federal Reserve to Protect the Payments System regarding access to the payments system for limited service or Skinny master accounts (Federal Reserve) Action Alert - Urge Your U.S. House Member to Support the Main Street Capital Access Act (H.R. 6955) (House) specifically regarding regulatory fairness, transparency and right-sizing; promoting healthy, growing, and competitive banking industry; and improving access to funding and capital for small to mid-sized banks (House) Action Alert - Urge Illinois Senators to Protect Community Bank Deposits in the CLARITY Act regarding disintermediation of community bank deposits from stablecoin issuers and exchanges from paying interest or rewards on stablecoin deposits (Senate) Miscellaneous - Check Fraud - Status of the results of the June of 2025 joint regulator Request For Information (RFI) on payments/check fraud (Fed, OCC and FDIC) AI - Awareness of the various issues surrounding its use (House)

CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Appropriate Regulation of Fintechs and Innovations in Financial Services The pace of innovation in financial services has been accelerating. Many of these new services are offered by financial technology companies - better known as fintechs. Financial innovation presents community banks with challenges and opportunities. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose unreasonable requirements on them, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Prescriptive and Intrusive FDIC Corporate Governance Guidelines In 2023, the FDIC proposed new corporate governance and risk management guidelines. Although the guidelines only apply to covered institutions with $10 billion or more in assets, these overly prescriptive guidelines apply the same set of standards to larger community banks as they do to the nations largest banks. These guidelines would make it even more difficult to attract new directors, particularly those in rural areas. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. De Novo Community Bank Formation, the Dual Banking System, and Charter Choice The chartering of many newly chartered (de novo) community banks is vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of continued banking industry consolidation. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, where chartering and supervision are divided between the federal government and the states, and where the federal government supervision and regulation is divided between the Federal Reserve, Office of Comptroller of the Currency, and the Federal Deposit Insurance Corporation. Community banks should be able to choose the banking charter and associated prudential regulator that best fits their unique needs and business model. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. Responsible Bank Merger Activity Some community banks have found it helpful to merge with other community banks to be able to spread the significant and escalating costs of regulatory compliance, cybersecurity, technology and innovation to remain highly competitive. Restrictive bank merger legislation or regulations should not apply to community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Insure) Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts Too-Big-To-Not-Insure The 2023 failures of Silicon Valley Bank and Signature Bank revealed that policymakers have created a new category of very large banks - Too-Big-To-Not-Insure (although they will fail) because the FDIC decided to insure 100% of the uninsured deposits of these two failed banks. There must be accountability by both the banks and the regulators for their respective failures. In the future, if systemically important financial institutions (SIFIs) cause losses to the DIF then SIFIs should be responsible for reimbursing the DIF for all the losses they created. Too-Big-To-Fail The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate, Federal Reserve, OCC and FDIC) Legislation and Regulation - H.R. 3633 or the CLARITY Act (All Sections) and S. 394 or the GENIUS Act (All Sections), S. 1582 or the GENIUS Act (All Sections) regarding stablecoins and ICBA/CBAI guiding principles (House, Senate, OCC) H.R. 1822 and S. 838 or the ACRE Act of 2025 (All Sections) to provide that interest income on loans to ag borrowers secured by ag assets or residences in ag areas will be considered exempt for income tax purposes (House and Senate) H.R. 2808 and S. 1467 or the Homebuyers Privacy Protection Act (All Sections) to protect the financial privacy of mortgage applicants by restricting the sale of trigger leads (House and Senate) S.J. Res 18 disapproving the CFPBs Rule related to overdraft lending for very large institutions (Senate) Letters - None Action Alerts - None Miscellaneous - Support for de novo bank formation, charter choice and the dual banking system (Senate) Recent reorganization of the OCC to combine the Midsized and Community Bank Supervision and Large Bank Supervision functions (OCC) OCCs Virtual Innovations Office Hours discussed FinTechs, digital assets, cryptocurrency, Special Purpose National Banks, third party risk management, stablecoins, and the disintermediation of community banks (OCC) The Independent Community Bankers of America (ICBA) 2025 Legislative Priorities discussed at the ICBA Capital Summit and CBAIs Call on Washington including - the CFPBs Section 1071 Rule, Major Tax Legislation, Taxing Credit Unions with Assets of More than $1 billion, Access to Credit for Rural Economies (ACRE) Act, Ensure Stablecoin Frameworks Dont Harm Community Banks, Oppose Credit Card Routing Mandates, Support for Agricultural Lending and Rural America, Support Community Bank Formation, Growth and Tiered Regulation and Restricting the Sale of Mortgage Trigger Leads (House and Senate) Congratulations to now Federal Reserve Vice Chair for Supervision, Miki Bowman, on her Senate confirmation (Federal Reserve) Statement for the Record submitted to the Senate Committee on the Judiciary for a hearing on elder fraud and scams (Senate) Statement of appreciation for the publication of a Request for Information (RFI) on Potential Actions to Address Payments Fraud (including check fraud) (Federal Reserve, FDIC and OCC)

CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate, Federal Reserve, OCC and FDIC) Legislation and Regulation - H.R. 3633 or the CLARITY Act (All Sections) and S. 394 or the GENIUS Act (All Sections), S. 1582 or the GENIUS Act (All Sections) regarding stablecoins and ICBA/CBAI guiding principles (House, Senate, OCC) H.R. 1822 and S. 838 or the ACRE Act of 2025 (All Sections) to provide that interest income on loans to ag borrowers secured by ag assets or residences in ag areas will be considered exempt for income tax purposes (House and Senate) Letters - None Action Alerts - None Miscellaneous - OCCs Virtual Innovations Office Hours discussed FinTechs, digital assets, cryptocurrency, Special Purpose National Banks, third party risk management, stablecoins, and the disintermediation of community banks (OCC) The Independent Community Bankers of America (ICBA) 2025 Legislative Priorities discussed at the ICBA Capital Summit and CBAIs Call on Washington including - the CFPBs Section 1071 Rule, Major Tax Legislation, Taxing Credit Unions with Assets of More than $1 billion, Access to Credit for Rural Economies (ACRE) Act, Ensure Stablecoin Frameworks Dont Harm Community Banks, Oppose Credit Card Routing Mandates, Support for Agricultural Lending and Rural America, Support Community Bank Formation, Growth and Tiered Regulation and Restricting the Sale of Mortgage Trigger Leads (House and Senate) Statement of appreciation for the publication of a Request for Information (RFI) on Potential Actions to Address Payments Fraud (including check fraud) (Federal Reserve, FDIC and OCC)

CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate, Federal Reserve, OCC and FDIC) Legislation and Regulation - H.R. 3633 or the CLARITY Act (All Sections) and S. 394 or the GENIUS Act (All Sections), S. 1582 or the GENIUS Act (All Sections) regarding stablecoins and ICBA/CBAI guiding principles (House, Senate, OCC) H.R. 1822 and S. 838 or the ACRE Act of 2025 (All Sections) to provide that interest income on loans to ag borrowers secured by ag assets or residences in ag areas will be considered exempt for income tax purposes (House and Senate) H.R. 2808 and S. 1467 or the Homebuyers Privacy Protection Act (All Sections) to protect the financial privacy of mortgage applicants by restricting the sale of trigger leads (House and Senate) S.J. Res 18 disapproving the CFPBs Rule related to overdraft lending for very large institutions (Senate) Letters - None Action Alerts - None Miscellaneous - OCCs Virtual Innovations Office Hours discussed FinTechs, digital assets, cryptocurrency, Special Purpose National Banks, third party risk management, stablecoins, and the disintermediation of community banks (OCC) The Independent Community Bankers of America (ICBA) 2025 Legislative Priorities discussed at the ICBA Capital Summit and CBAIs Call on Washington including - the CFPBs Section 1071 Rule, Major Tax Legislation, Taxing Credit Unions with Assets of More than $1 billion, Access to Credit for Rural Economies (ACRE) Act, Ensure Stablecoin Frameworks Dont Harm Community Banks, Oppose Credit Card Routing Mandates, Support for Agricultural Lending and Rural America, Support Community Bank Formation, Growth and Tiered Regulation and Restricting the Sale of Mortgage Trigger Leads (House and Senate) Statement for the Record submitted to the Senate Committee on the Judiciary for a hearing on elder fraud and scams (Senate) Statement of appreciation for the publication of a Request for Information (RFI) on Potential Actions to Address Payments Fraud (including check fraud) (Federal Reserve, FDIC and OCC)

CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate, Federal Reserve, OCC and FDIC) Legislation and Regulation - H.R. 3633 or the CLARITY Act (All Sections) and S. 394 or the GENIUS Act (All Sections), S. 1582 or the GENIUS Act (All Sections) regarding stablecoins and ICBA/CBAI guiding principles (House, Senate, OCC) H.R. 1822 and S. 838 or the ACRE Act of 2025 (All Sections) to provide that interest income on loans to ag borrowers secured by ag assets or residences in ag areas will be considered exempt for income tax purposes (House and Senate) Action Alerts - None Miscellaneous - OCCs Virtual Innovations Office Hours discussed FinTechs, digital assets, cryptocurrency, Special Purpose National Banks, third party risk management, stablecoins, and the disintermediation of community banks (OCC) The Independent Community Bankers of America (ICBA) 2025 Legislative Priorities discussed at the ICBA Capital Summit and CBAIs Call on Washington including - the CFPBs Section 1071 Rule, Major Tax Legislation, Taxing Credit Unions with Assets of More than $1 billion, Access to Credit for Rural Economies (ACRE) Act, Ensure Stablecoin Frameworks Dont Harm Community Banks, Oppose Credit Card Routing Mandates, Support for Agricultural Lending and Rural America, Support Community Bank Formation, Growth and Tiered Regulation and Restricting the Sale of Mortgage Trigger Leads (House and Senate) Statement of appreciation for the publication of a Request for Information (RFI) on Potential Actions to Address Payments Fraud (including check fraud) (Federal Reserve, FDIC and OCC)

CBAI Federal Policy Priorities - Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 1822 and S. 838 or the ACRE Act of 2025 (All Sections) to provide that interest income on loans to ag borrowers secured by ag assets or residences in ag areas will be considered exempt for income tax purposes (House and Senate) Letters - None Action Alerts - None Miscellaneous - The Independent Community Bankers of America (ICBA) 2025 Legislative Priorities discussed at the ICBA Capital Summit and CBAIs Call on Washington including - the CFPBs Section 1071 Rule, Major Tax Legislation, Taxing Credit Unions with Assets of More than $1 billion, Access to Credit for Rural Economies (ACRE) Act, Ensure Stablecoin Frameworks Dont Harm Community Banks, Oppose Credit Card Routing Mandates, Support for Agricultural Lending and Rural America, Support Community Bank Formation, Growth and Tiered Regulation and Restricting the Sale of Mortgage Trigger Leads (House and Senate)

CBAI Federal Policy Priorities - Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 1822 and S. 838 or the ACRE Act of 2025 (All Sections) to provide that interest income on loans to ag borrowers secured by ag assets or residences in ag areas will be considered exempt for income tax purposes (House and Senate) Letters - None Action Alerts - None Miscellaneous - The Independent Community Bankers of America (ICBA) 2025 Legislative Priorities discussed at the ICBA Capital Summit and CBAIs Call on Washington including - the CFPBs Section 1071 Rule, Major Tax Legislation, Taxing Credit Unions with Assets of More than $1 billion, Access to Credit for Rural Economies (ACRE) Act, Ensure Stablecoin Frameworks Dont Harm Community Banks, Oppose Credit Card Routing Mandates, Support for Agricultural Lending and Rural America, Support Community Bank Formation, Growth and Tiered Regulation and Restricting the Sale of Mortgage Trigger Leads (House and Senate)

CBAI Federal Policy Priorities - Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate, Federal Reserve, OCC and FDIC) Legislation and Regulation - H.R. 1822 and S. 838 or the ACRE Act of 2025 (All Sections) to provide that interest income on loans to ag borrowers secured by ag assets or residences in ag areas will be considered exempt for income tax purposes (House and Senate) Letters - None Action Alerts - None Miscellaneous - The Independent Community Bankers of America (ICBA)guiding principles for the 119th Congress titled Transforming Regulation for Growth: The Community Bank Agenda including - Fix Destructive Regulatory Burden, Ensuring a Competitive Financial Landscape, Revitalizing Rural America and Strengthening Financial Consumers (House and Senate) Meetings in D.C. with the Federal Reserve, FDIC and OCC regarding - deposit check fraud, stablecoin legislation in the House and Senate, the ACRE Act (H.R. 1822 and S. 838), industrial loan companies (ILCs) and special purpose banking charters, and the expansionist agenda of credit unions and the Farm Credit System (FCS) (Federal Reserve, FDIC and OCC)

CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Appropriate Regulation of Fintechs and Innovations in Financial Services The pace of innovation in financial services has been accelerating. Many of these new services are offered by financial technology companies - better known as fintechs. Financial innovation presents community banks with challenges and opportunities. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose unreasonable requirements on them, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Prescriptive and Intrusive FDIC Corporate Governance Guidelines In 2023, the FDIC proposed new corporate governance and risk management guidelines. Although the guidelines only apply to covered institutions with $10 billion or more in assets, these overly prescriptive guidelines apply the same set of standards to larger community banks as they do to the nations largest banks. These guidelines would make it even more difficult to attract new directors, particularly those in rural areas. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. De Novo Community Bank Formation, the Dual Banking System, and Charter Choice The chartering of many newly chartered (de novo) community banks is vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of continued banking industry consolidation. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, where chartering and supervision are divided between the federal government and the states, and where the federal government supervision and regulation is divided between the Federal Reserve, Office of Comptroller of the Currency, and the Federal Deposit Insurance Corporation. Community banks should be able to choose the banking charter and associated prudential regulator that best fits their unique needs and business model. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. Responsible Bank Merger Activity Some community banks have found it helpful to merge with other community banks to be able to spread the significant and escalating costs of regulatory compliance, cybersecurity, technology and innovation to remain highly competitive. Restrictive bank merger legislation or regulations should not apply to community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Insure) Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts Too-Big-To-Not-Insure The 2023 failures of Silicon Valley Bank and Signature Bank revealed that policymakers have created a new category of very large banks - Too-Big-To-Not-Insure (although they will fail) because the FDIC decided to insure 100% of the uninsured deposits of these two failed banks. There must be accountability by both the banks and the regulators for their respective failures. In the future, if systemically important financial institutions (SIFIs) cause losses to the DIF then SIFIs should be responsible for reimbursing the DIF for all the losses they created. Too-Big-To-Fail The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate, Federal Reserve, OCC and FDIC) Legislation and Regulation - H.R. 7403 in the 118th Congress or the Bank Failure Prevention Act of 2024 (All Sections) to revise the Federal Reserve Boards review process of mergers and acquisitions for bank holding companies (House) H.J. Res. 59 disapproving the rule submitted by the CFPB related to overdraft lending for very large institutions (House) H.R. 2392 or the STABLE Act of 2025 (All Sections) and S. 394 or the GENIUS Act of 2025 (All Sections) regarding stablecoins and ICBA/CBAI guiding principles (House and FDIC) H.R. 1822 and S. 838 or the ACRE Act of 2025 (All Sections) to provide that interest income on loans to ag borrowers secured by ag assets or residences in ag areas will be considered exempt for income tax purposes (House and Senate) Letters - Letter to the Federal prudential banking regulator (OCC, Federal Reserve and FDIC) regarding Deposit Check Fraud - The prompt and reasonable reimbursements for community banks from the largest banks for fraudulently altered return checks - the largest banks opening fraudulent accounts into which fraud items are being deposited - joint supervisory guidance to address the largest banks apparent management and compliance lapses - enhanced supervision, regulation and enforcement against the largest banks for CDD and CIP compliance (House and Senate, Federal Reserve, OCC and FDIC) Letter to the U. S. Department of the Treasury regarding the nomination of Federal Reserve Governor Bowman for Vice Chair of Supervision (Department of Treasury) Action Alerts - None Miscellaneous - The Independent Community Bankers of America (ICBA)guiding principles for the 119th Congress titled Transforming Regulation for Growth: The Community Bank Agenda including - Fix Destructive Regulatory Burden, Ensuring a Competitive Financial Landscape, Revitalizing Rural America and Strengthening Financial Consumers (House and Senate) Oral Comments during the EGRPRA Review discussing Applications and Reporting including - de novo community banks, industrial loan companies (ILCs) and special purpose banking charters (OCC, Federal Reserve and FDIC) Meetings in D.C. with the Federal Reserve, FDIC and OCC regarding - deposit check fraud, stablecoin legislation in the House and Senate, the ACRE Act (H.R. 1822 and S. 838), industrial loan companies (ILCs) and special purpose banking charters, and the expansionist agenda of credit unions and the Farm Credit System (FCS) (Federal Reserve, FDIC and OCC)

CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Appropriate Regulation of Fintechs and Innovations in Financial Services The pace of innovation in financial services has been accelerating. Many of these new services are offered by financial technology companies - better known as fintechs. Financial innovation presents community banks with challenges and opportunities. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose unreasonable requirements on them, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Prescriptive and Intrusive FDIC Corporate Governance Guidelines In 2023, the FDIC proposed new corporate governance and risk management guidelines. Although the guidelines only apply to covered institutions with $10 billion or more in assets, these overly prescriptive guidelines apply the same set of standards to larger community banks as they do to the nations largest banks. These guidelines would make it even more difficult to attract new directors, particularly those in rural areas. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. De Novo Community Bank Formation, the Dual Banking System, and Charter Choice The chartering of many newly chartered (de novo) community banks is vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of continued banking industry consolidation. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, where chartering and supervision are divided between the federal government and the states, and where the federal government supervision and regulation is divided between the Federal Reserve, Office of Comptroller of the Currency, and the Federal Deposit Insurance Corporation. Community banks should be able to choose the banking charter and associated prudential regulator that best fits their unique needs and business model. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. Responsible Bank Merger Activity Some community banks have found it helpful to merge with other community banks to be able to spread the significant and escalating costs of regulatory compliance, cybersecurity, technology and innovation to remain highly competitive. Restrictive bank merger legislation or regulations should not apply to community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Insure) Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts Too-Big-To-Not-Insure The 2023 failures of Silicon Valley Bank and Signature Bank revealed that policymakers have created a new category of very large banks - Too-Big-To-Not-Insure (although they will fail) because the FDIC decided to insure 100% of the uninsured deposits of these two failed banks. There must be accountability by both the banks and the regulators for their respective failures. In the future, if systemically important financial institutions (SIFIs) cause losses to the DIF then SIFIs should be responsible for reimbursing the DIF for all the losses they created. Too-Big-To-Fail The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate, Federal Reserve, OCC and FDIC) Legislation and Regulation - H.R. 7403 in the 118th Congress or the Bank Failure Prevention Act of 2024 (All Sections) to revise the Federal Reserve Boards review process of mergers and acquisitions for bank holding companies (House) H.J. Res. 59 disapproving the rule submitted by the CFPB related to overdraft lending for very large institutions (House) H.R. 2392 or the STABLE Act of 2025 (All Sections) and S. 394 or the GENIUS Act of 2025 (All Sections) regarding stablecoins and ICBA/CBAI guiding principles (House and FDIC) H.R. 1822 and S. 838 or the ACRE Act of 2025 (All Sections) to provide that interest income on loans to ag borrowers secured by ag assets or residences in ag areas will be considered exempt for income tax purposes (House and Senate) Letters - Letter to the Federal prudential banking regulator (OCC, Federal Reserve and FDIC) regarding Deposit Check Fraud - The prompt and reasonable reimbursements for community banks from the largest banks for fraudulently altered return checks - the largest banks opening fraudulent accounts into which fraud items are being deposited - joint supervisory guidance to address the largest banks apparent management and compliance lapses - enhanced supervision, regulation and enforcement against the largest banks for CDD and CIP compliance (House and Senate, Federal Reserve, OCC and FDIC) Letter to the U. S. Department of the Treasury regarding the nomination of Federal Reserve Governor Bowman for Vice Chair of Supervision (Department of Treasury) Action Alerts - None Miscellaneous - The Independent Community Bankers of America (ICBA)guiding principles for the 119th Congress titled Transforming Regulation for Growth: The Community Bank Agenda including - Fix Destructive Regulatory Burden, Ensuring a Competitive Financial Landscape, Revitalizing Rural America and Strengthening Financial Consumers (House and Senate) Oral Comments during the EGRPRA Review discussing Applications and Reporting including - de novo community banks, industrial loan companies (ILCs) and special purpose banking charters (OCC, Federal Reserve and FDIC) Meetings in D.C. with the Federal Reserve, FDIC and OCC regarding - deposit check fraud, stablecoin legislation in the House and Senate, the ACRE Act (H.R. 1822 and S. 838), industrial loan companies (ILCs) and special purpose banking charters, and the expansionist agenda of credit unions and the Farm Credit System (FCS) (Federal Reserve, FDIC and OCC)

CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate, Federal Reserve, OCC and FDIC) Legislation and Regulation - H.R. 2392 or the STABLE Act of 2025 (All Sections) and S. 394 or the GENIUS Act of 2025 (All Sections) regarding stablecoins and ICBA/CBAI guiding principles (House and FDIC) H.R. 1822 and S. 838 or the ACRE Act of 2025 (All Sections) to provide that interest income on loans to ag borrowers secured by ag assets or residences in ag areas will be considered exempt for income tax purposes (House and Senate) Letters - Letter to the Federal prudential banking regulators (OCC, Federal Reserve and FDIC) regarding Deposit Check Fraud - The prompt and reasonable reimbursements for community banks from the largest banks for fraudulently altered return checks - the largest banks opening fraudulent accounts into which fraud items are being deposited - joint supervisory guidance to address the largest banks apparent management and compliance lapses - enhanced supervision, regulation and enforcement against the largest banks for CDD and CIP compliance (House and Senate, Federal Reserve, OCC and FDIC) Action Alerts - None Miscellaneous - The Independent Community Bankers of America (ICBA)guiding principles for the 119th Congress titled Transforming Regulation for Growth: The Community Bank Agenda including - Fix Destructive Regulatory Burden, Ensuring a Competitive Financial Landscape, Revitalizing Rural America and Strengthening Financial Consumers (House and Senate) Meetings in D.C. with the Federal Reserve, FDIC and OCC regarding - deposit check fraud, stablecoin legislation in the House and Senate, the ACRE Act (H.R. 1832 and S. 838), industrial loan companies (ILCs) and special purpose banking charters, and the expansionist agenda of credit unions and the Farm Credit System (FCS) (Federal Reserve, FDIC and OCC)

CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate, Federal Reserve, OCC and FDIC) Legislation and Regulation - H.J. Res. 59 disapproving the rule submitted by the CFPB related to overdraft lending for very large institutions (House) H.R. 2392 or the STABLE Act of 2025 (All Sections) and S. 394 or the GENIUS Act of 2025 (All Sections) regarding stablecoins and ICBA/CBAI guiding principles (House and FDIC) H.R. 1822 and S. 838 or the ACRE Act of 2025 (All Sections) to provide that interest income on loans to ag borrowers secured by ag assets or residences in ag areas will be considered exempt for income tax purposes (House and Senate) Letters - Letter to the Federal prudential banking regulators (OCC, Federal Reserve and FDIC) regarding Deposit Check Fraud - The prompt and reasonable reimbursements for community banks from the largest banks for fraudulently altered return checks - the largest banks opening fraudulent accounts into which fraud items are being deposited - joint supervisory guidance to address the largest banks apparent management and compliance lapses - enhanced supervision, regulation and enforcement against the largest banks for CDD and CIP compliance (House and Senate, Federal Reserve, OCC and FDIC) Action Alerts - None Miscellaneous - The Independent Community Bankers of America (ICBA)guiding principles for the 119th Congress titled Transforming Regulation for Growth: The Community Bank Agenda including - Fix Destructive Regulatory Burden, Ensuring a Competitive Financial Landscape, Revitalizing Rural America and Strengthening Financial Consumers (House and Senate) Meetings in D.C. with the Federal Reserve, FDIC and OCC regarding - deposit check fraud, stablecoin legislation in the House and Senate, the ACRE Act (H.R. 1832 and S. 838), industrial loan companies (ILCs) and special purpose banking charters, and the expansionist agenda of credit unions and the Farm Credit System (FCS) (Federal Reserve, FDIC and OCC)

CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate, Federal Reserve, OCC and FDIC) Legislation and Regulation - H.R. 2392 or the STABLE Act of 2025 (All Sections) and S. 394 or the GENIUS Act of 2025 (All Sections) regarding stablecoins and ICBA/CBAI guiding principles (House and FDIC) H.R. 1822 and S. 838 or the ACRE Act of 2025 (All Sections) to provide that interest income on loans to ag borrowers secured by ag assets or residences in ag areas will be considered exempt for income tax purposes (House and Senate) Letters - Letter to the Federal prudential banking regulators (OCC, Federal Reserve and FDIC) regarding Deposit Check Fraud - The prompt and reasonable reimbursements for community banks from the largest banks for fraudulently altered return checks - the largest banks opening fraudulent accounts into which fraud items are being deposited - joint supervisory guidance to address the largest banks apparent management and compliance lapses - enhanced supervision, regulation and enforcement against the largest banks for CDD and CIP compliance (House and Senate, Federal Reserve, OCC and FDIC) Action Alerts - None Miscellaneous - The Independent Community Bankers of America (ICBA)guiding principles for the 119th Congress titled Transforming Regulation for Growth: The Community Bank Agenda including - Fix Destructive Regulatory Burden, Ensuring a Competitive Financial Landscape, Revitalizing Rural America and Strengthening Financial Consumers (House and Senate) Oral Comments during the EGRPRA Review discussing Applications and Reporting including - de novo community banks, industrial loan companies (ILCs) and special purpose banking charters (OCC, Federal Reserve and FDIC) Meetings in D.C. with the Federal Reserve, FDIC and OCC regarding - deposit check fraud, stablecoin legislation in the House and Senate, the ACRE Act (H.R. 1832 and S. 838), industrial loan companies (ILCs) and special purpose banking charters, and the expansionist agenda of credit unions and the Farm Credit System (FCS) (Federal Reserve, FDIC and OCC)

CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Appropriate Regulation of Fintechs and Innovations in Financial Services The pace of innovation in financial services has been accelerating. Many of these new services are offered by financial technology companies - better known as fintechs. Financial innovation presents community banks with challenges and opportunities. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose unreasonable requirements on them, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Prescriptive and Intrusive FDIC Corporate Governance Guidelines In 2023, the FDIC proposed new corporate governance and risk management guidelines. Although the guidelines only apply to covered institutions with $10 billion or more in assets, these overly prescriptive guidelines apply the same set of standards to larger community banks as they do to the nations largest banks. These guidelines would make it even more difficult to attract new directors, particularly those in rural areas. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. De Novo Community Bank Formation, the Dual Banking System, and Charter Choice The chartering of many newly chartered (de novo) community banks is vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of continued banking industry consolidation. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, where chartering and supervision are divided between the federal government and the states, and where the federal government supervision and regulation is divided between the Federal Reserve, Office of Comptroller of the Currency, and the Federal Deposit Insurance Corporation. Community banks should be able to choose the banking charter and associated prudential regulator that best fits their unique needs and business model. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. Responsible Bank Merger Activity Some community banks have found it helpful to merge with other community banks to be able to spread the significant and escalating costs of regulatory compliance, cybersecurity, technology and innovation to remain highly competitive. Restrictive bank merger legislation or regulations should not apply to community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Insure) Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts Too-Big-To-Not-Insure The 2023 failures of Silicon Valley Bank and Signature Bank revealed that policymakers have created a new category of very large banks - Too-Big-To-Not-Insure (although they will fail) because the FDIC decided to insure 100% of the uninsured deposits of these two failed banks. There must be accountability by both the banks and the regulators for their respective failures. In the future, if systemically important financial institutions (SIFIs) cause losses to the DIF then SIFIs should be responsible for reimbursing the DIF for all the losses they created. Too-Big-To-Fail The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate, OCC, FDIC) Legislation and Regulation - H.R. 10045 (All Sections) to provide emergency assistance to producers of eligible commodities for which the expected revenue on crop year 2024 is below projections (House) H.R. 3139 or the ACRE Act (All Sections) to provide that interest income on loans to ag borrowers secured by ag assets or residences in ag areas will be considered exempt for income tax purposes (House) S. 3502 or the Homebuyers Privacy Protection Act (Senate) (All Sections) and H.R. 7297 (House) (All Sections) are bills to prohibit credit reporting agencies from providing a credit report not initiated by a consumer if the report is being provided on the basis that the consumer has had a credit inquiry regarding a home mortgage loan. This practice, known as producing a trigger lead, provides notice to other mortgage lenders that the consumer is seeking a mortgage loan (Senate and House) S. 1838 or the Credit Card Competition Act (All Sections) to provide competition into the routing of credit card transactions (Senate) Letters - Comment Letter to the FDIC regarding Industrial Loan Companies (ILCs): NPR - Parent Companies of Industrial Banks and Industrial Loan Companies; RIN 3064-AF88 (FDIC) Comment Letter to the OCC, FDIC and the Federal Reserve regarding the EGRPRA Review concerning tiered regulations, consumer protections, directors/officers/employees, money laundering/BSA/AML, FinCEN and BOI reporting, and check fraud and reimbursements for community banks (OCC, FDIC, Federal Reserve) Comment Letter to the FDIC regarding brokered Deposits: NPR - Unsafe and Unsound Banking Practices; Brokered Deposit Restrictions - RIN 3064-AF99 (FDIC) Comment Letter to the Federal Reserve regarding Discount Window Borrowings: RFI - Operational Aspects of Federal Reserve Bank Extensions of thew Discount Window and Intraday Credit - Docket No. OP-1838 (Federal Reserve) Action Alerts - None Miscellaneous - Complaint to the Farm Credit Administrations Office of Inspector General regarding alleged illegal residential mortgage loan made by an FCS lender in a town which has a population in excess of 10,000 people which would be in violation of FCSs residential mortgage lending authority (Farm Credit) Concerns expressed to the Federal Housing Finance Agency regarding their Advisory Bulletin that focuses on credit risk management expectations for FHLBs (FHFA) Deposit Check Fraud - The prompt and reasonable reimbursements for community banks from the largest banks for fraudulently altered return checks, and the largest banks opening fraudulent accounts into which fraud items are being deposited, including - joint supervisory guidance addressed to the largest banks for their apparent management and compliance lapses, enhanced supervision, regulation and enforcement against the largest banks for CDD and CIP compliance - retaining the OCCs check fraud complaint email address (portal) - escalating complaints member resource - U.S. House member letter to the banking regulators, NCUA and FinCEN requesting briefing (House, OCC, Federal Reserve) Concerns expressed to the FDIC and OCC regarding the harmful impact of other agencys (i.e., CFPB and FHFA) rulemaking and policies on the banks these prudential regulators regulate for safety and soundness (FDIC and OCC)

CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate, OCC, FDIC) Legislation and Regulation - H.R. 3139 or the ACRE Act (All Sections) to provide that interest income on loans to ag borrowers secured by ag assets or residences in ag areas will be considered exempt for income tax purposes (House) S. 1838 or the Credit Card Competition Act (All Sections) to provide competition into the routing of credit card transactions (Senate) Letters - Comment Letter to the OCC, FDIC and the Federal Reserve regarding the EGRPRA Review concerning tiered regulations, consumer protections, directors/officers/employees, money laundering/BSA/AML, FinCEN and BOI reporting, and check fraud and reimbursements for community banks (OCC, FDIC, Federal Reserve) Action Alerts - None Miscellaneous - Deposit Check Fraud - The prompt and reasonable reimbursements for community banks from the largest banks for fraudulently altered return checks, and the largest banks opening fraudulent accounts into which fraud items are being deposited, including - joint supervisory guidance addressed to the largest banks for their apparent management and compliance lapses, enhanced supervision, regulation and enforcement against the largest banks for CDD and CIP compliance - retaining the OCCs check fraud complaint email address (portal) - escalating complaints member resource - U.S. House member letter to the banking regulators, NCUA and FinCEN requesting briefing (House, OCC, Federal Reserve)

CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Appropriate Regulation of Fintechs and Innovations in Financial Services The pace of innovation in financial services has been accelerating. Many of these new services are offered by financial technology companies - better known as fintechs. Financial innovation presents community banks with challenges and opportunities. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose unreasonable requirements on them, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Prescriptive and Intrusive FDIC Corporate Governance Guidelines In 2023, the FDIC proposed new corporate governance and risk management guidelines. Although the guidelines only apply to covered institutions with $10 billion or more in assets, these overly prescriptive guidelines apply the same set of standards to larger community banks as they do to the nations largest banks. These guidelines would make it even more difficult to attract new directors, particularly those in rural areas. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. De Novo Community Bank Formation, the Dual Banking System, and Charter Choice The chartering of many newly chartered (de novo) community banks is vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of continued banking industry consolidation. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, where chartering and supervision are divided between the federal government and the states, and where the federal government supervision and regulation is divided between the Federal Reserve, Office of Comptroller of the Currency, and the Federal Deposit Insurance Corporation. Community banks should be able to choose the banking charter and associated prudential regulator that best fits their unique needs and business model. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. Responsible Bank Merger Activity Some community banks have found it helpful to merge with other community banks to be able to spread the significant and escalating costs of regulatory compliance, cybersecurity, technology and innovation to remain highly competitive. Restrictive bank merger legislation or regulations should not apply to community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Insure) Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts Too-Big-To-Not-Insure The 2023 failures of Silicon Valley Bank and Signature Bank revealed that policymakers have created a new category of very large banks - Too-Big-To-Not-Insure (although they will fail) because the FDIC decided to insure 100% of the uninsured deposits of these two failed banks. There must be accountability by both the banks and the regulators for their respective failures. In the future, if systemically important financial institutions (SIFIs) cause losses to the DIF then SIFIs should be responsible for reimbursing the DIF for all the losses they created. Too-Big-To-Fail The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate, OCC, FDIC) Legislation and Regulation - H.R. 10045 (All Sections) to provide emergency assistance to producers of eligible commodities for which the expected revenue on crop year 2024 is below projections (House) H.R. 3139 or the ACRE Act (All Sections) to provide that interest income on loans to ag borrowers secured by ag assets or residences in ag areas will be considered exempt for income tax purposes (House) S. 3502 or the Homebuyers Privacy Protection Act (Senate) (All Sections) and H.R. 7297 (House) (All Sections) are bills to prohibit credit reporting agencies from providing a credit report not initiated by a consumer if the report is being provided on the basis that the consumer has had a credit inquiry regarding a home mortgage loan. This practice, known as producing a trigger lead, provides notice to other mortgage lenders that the consumer is seeking a mortgage loan (Senate and House) S. 1838 or the Credit Card Competition Act (All Sections) to provide competition into the routing of credit card transactions (Senate) Letters - Comment Letter to the FDIC regarding Industrial Loan Companies (ILCs): NPR - Parent Companies of Industrial Banks and Industrial Loan Companies; RIN 3064-AF88 (FDIC) Comment Letter to the OCC, FDIC and the Federal Reserve regarding the EGRPRA Review concerning tiered regulations, consumer protections, directors/officers/employees, money laundering/BSA/AML, FinCEN and BOI reporting, and check fraud and reimbursements for community banks (OCC, FDIC, Federal Reserve) Comment Letter to the FDIC regarding brokered Deposits: NPR - Unsafe and Unsound Banking Practices; Brokered Deposit Restrictions - RIN 3064-AF99 (FDIC) Comment Letter to the Federal Reserve regarding Discount Window Borrowings: RFI - Operational Aspects of Federal Reserve Bank Extensions of thew Discount Window and Intraday Credit - Docket No. OP-1838 (Federal Reserve) Action Alerts - None Miscellaneous - Complaint to the Farm Credit Administrations Office of Inspector General regarding alleged illegal residential mortgage loan made by an FCS lender in a town which has a population in excess of 10,000 people which would be in violation of FCSs residential mortgage lending authority (Farm Credit) Concerns expressed to the Federal Housing Finance Agency regarding their Advisory Bulletin that focuses on credit risk management expectations for FHLBs (FHFA) Deposit Check Fraud - The prompt and reasonable reimbursements for community banks from the largest banks for fraudulently altered return checks, and the largest banks opening fraudulent accounts into which fraud items are being deposited, including - joint supervisory guidance addressed to the largest banks for their apparent management and compliance lapses, enhanced supervision, regulation and enforcement against the largest banks for CDD and CIP compliance - retaining the OCCs check fraud complaint email address (portal) - escalating complaints member resource - U.S. House member letter to the banking regulators, NCUA and FinCEN requesting briefing (House, OCC, Federal Reserve) Concerns expressed to the FDIC and OCC regarding the harmful impact of other agencys (i.e., CFPB and FHFA) rulemaking and policies on the banks these prudential regulators regulate for safety and soundness (FDIC and OCC)

CBAI Federal Policy Priorities - Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate, FDIC, OCC) Legislation and Regulation - H.R. 3139 or the ACRE Act (All Sections) to provide that interest income on loans to ag borrowers secured by ag assets or residences in ag areas will be considered exempt for income tax purposes (House) Letters - None Action Alerts - None Miscellaneous - None

CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate, OCC, FDIC) Legislation and Regulation - H.R. 3139 or the ACRE Act (All Sections) to provide that interest income on loans to ag borrowers secured by ag assets or residences in ag areas will be considered exempt for income tax purposes (House) S. 3502 or the Homebuyers Privacy Protection Act (Senate) (All Sections) and H.R. 7297 (House) (All Sections) are bills to prohibit credit reporting agencies from providing a credit report not initiated by a consumer if the report is being provided on the basis that the consumer has had a credit inquiry regarding a home mortgage loan. This practice, known as producing a trigger lead, provides notice to other mortgage lenders that the consumer is seeking a mortgage loan. (Senate and House) S. 1838 or the Credit Card Competition Act (All Sections) to provide competition into the routing of credit card transactions (Senate) Letters - Comment Letter to the OCC, FDIC and the Federal Reserve regarding the EGRPRA Review concerning tiered regulations, consumer protections, directors/officers/employees, money laundering/BSA/AML, FinCEN and BOI reporting, and check fraud and reimbursements for community banks (OCC, FDIC, Federal Reserve) Action Alerts - None Miscellaneous - Complaint to the Farm Credit Administrations Office of Inspector General regarding alleged illegal residential mortgage loan made by an FCS lender in a town which has a population in excess of 10,000 people which would be in violation of FCSs residential mortgage lending authority (Farm Credit) Deposit Check Fraud - The prompt and reasonable reimbursements for community banks from the largest banks for fraudulently altered return checks, and the largest banks opening fraudulent accounts into which fraud items are being deposited, including - joint supervisory guidance addressed to the largest banks for their apparent management and compliance lapses, enhanced supervision, regulation and enforcement against the largest banks for CDD and CIP compliance - retaining the OCCs check fraud complaint email address (portal) - escalating complaints member resource - U.S. House member letter to the banking regulators, NCUA and FinCEN requesting briefing (House, OCC, Federal Reserve)

CBAI Federal Policy Priorities - Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate, FDIC, OCC) Legislation and Regulation - H.R. 3139 or the ACRE Act (All Sections) to provide that interest income on loans to ag borrowers secured by ag assets or residences in ag areas will be considered exempt for income tax purposes (House) Letters - None Action Alerts - None Miscellaneous - None

CBAI Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau (CFPB) Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states, is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for Housing Government Sponsored Entity (GSE) Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Responsible Bank Merger Activity New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Legitimate Bank Service Charges and Fees are not Exploitive and Junk Fees CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Realistic Perspective on Financial Inclusion CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks. SBA Direct Lending Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Postal Banking Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking Public banking (i.e., publicly owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Federal Home Loan Banks in their Comprehensive Review Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. The results of the Comprehensive Review by the FHFA should not disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Rules and Implementation Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished completely and expeditiously. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve - and must be closed. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Appropriate Regulations of Fintechs and Innovation in Financial Services Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Harmful Climate Risk Regulations CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. (House and Senate) Legislation and Regulation - S. 3502 (and Amendment 2358 to the NDA) - Homebuyers Privacy Protection Act (Senate) (All Sections) and H.R. 7297 - Trigger Leads Abatement Act (House) (All Sections) are bills to prohibit credit reporting agencies from providing a credit report not initiated by a consumer if the report is being provided on the basis that the consumer has had a credit inquiry regarding a home mortgage loan. This practice, known as producing a trigger lead, provides notice to other mortgage lenders that the consumer is seeking a mortgage loan. (Senate and House) H.R. 9303 and S. 4943 (All Sections) to protect consumers who are defrauded when they make payments (House and Senate) EGRPRA - Oral Comments During the EGRPRA Review concerning Anti Money Laundering, CTR and SAR reporting thresholds, Beneficial Ownership Interest reporting to FinCEN, and check fraud (FDIC, OCC, Federal Reserve) Letters - Comment Letter to the FHFA regarding Request for Input: Federal Home Loan Bank core mission and mission achievement (FHFA, FDIC, OCC, Federal Reserve) Comment Letter to the CFPB Regarding Proposed Rule - Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information [Debt] - Docket No. CFPB-2024-0023 and RIN 3170-AA54 (CFPB, FDIC, OCC, Federal Reserve) Action Alerts - Action Alert - Urge the Senate to pass S. 3502 (and Amendment 2358 to the NDA) - Homebuyers Privacy Protection Act (All Sections) a bill to prohibit credit reporting agencies from providing a credit report not initiated by a consumer if the report is being provided on the basis that the consumer has had a credit inquiry regarding a home mortgage loan. This practice, known as producing a trigger lead, provides notice to other mortgage lenders that the consumer is seeking a mortgage loan. (Senate) Miscellaneous - Deposit Check Fraud - The prompt and reasonable reimbursements for community banks from the largest banks for fraudulently altered return checks, and the largest banks opening fraudulent accounts into which fraud items are being deposited, including - joint supervisory guidance addressed to the largest banks for their apparent management and compliance lapses, enhanced supervision, regulation and enforcement against the largest banks for CDD and CIP compliance (OCC)

CBAI Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Current Issues, Opportunities and Concerns Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Reasonable Rules and Implementation Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. (House and Senate) Legislation and Regulation - None Letters - None Action Alerts - None Miscellaneous - None

CBAI Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Current Issues, Opportunities and Concerns Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Reasonable Rules and Implementation Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. (House and Senate) Legislation and Regulation - Letters - Comment Letter to the FHFA regarding Request for Input: Federal Home Loan Bank core mission and mission achievement (FHFA, FDIC, OCC, Federal Reserve) Action Alerts - None Miscellaneous - None

CBAI Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau (CFPB) Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks. SBA Direct Lending Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Reasonable Rules and Implementation Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished completely and expeditiously. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Harmful Climate Risk Regulations CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. (House and Senate) Legislation and Regulation - EGRPRA - Oral Comments During the EGRPRA Review concerning Anti Money Laundering, CTR and SAR reporting thresholds, Beneficial Ownership Interest reporting to FinCEN, and check fraud (FDIC, OCC, Federal Reserve) Letters - None Action Alerts - None Miscellaneous - Deposit Check Fraud - The prompt and reasonable reimbursements for community banks from the largest banks for fraudulently altered return checks, and the largest banks opening fraudulent accounts into which fraud items are being deposited, including - joint supervisory guidance addressed to the largest banks for their apparent management and compliance lapses, enhanced supervision, regulation and enforcement against the largest banks for CDD and CIP compliance (OCC)

CBAI Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau (CFPB) Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states, is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for Housing Government Sponsored Entity (GSE) Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Responsible Bank Merger Activity New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Legitimate Bank Service Charges and Fees are not Exploitive and Junk Fees CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Realistic Perspective on Financial Inclusion CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks. SBA Direct Lending Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Postal Banking Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking Public banking (i.e., publicly owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Federal Home Loan Banks in their Comprehensive Review Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. The results of the Comprehensive Review by the FHFA should not disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Rules and Implementation Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished completely and expeditiously. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve - and must be closed. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Appropriate Regulations of Fintechs and Innovation in Financial Services Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Harmful Climate Risk Regulations CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. (House and Senate) Legislation and Regulation - S. 3502 (and Amendment 2358 to the NDA) - Homebuyers Privacy Protection Act (Senate) (All Sections) and H.R. 7297 - Trigger Leads Abatement Act (House) (All Sections) are bills to prohibit credit reporting agencies from providing a credit report not initiated by a consumer if the report is being provided on the basis that the consumer has had a credit inquiry regarding a home mortgage loan. This practice, known as producing a trigger lead, provides notice to other mortgage lenders that the consumer is seeking a mortgage loan. (Senate and House) H.R. 9303 and S. 4943 (All Sections) to protect consumers who are defrauded when they make payments (House and Senate) EGRPRA - Oral Comments During the EGRPRA Review concerning Anti Money Laundering, CTR and SAR reporting thresholds, Beneficial Ownership Interest reporting to FinCEN, and check fraud (FDIC, OCC, Federal Reserve) Letters - Comment Letter to the FHFA regarding Request for Input: Federal Home Loan Bank core mission and mission achievement (FHFA, FDIC, OCC, Federal Reserve) Comment Letter to the CFPB Regarding Proposed Rule - Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information [Debt] - Docket No. CFPB-2024-0023 and RIN 3170-AA54 (CFPB, FDIC, OCC, Federal Reserve) Action Alerts - Action Alert - Urge the Senate to pass S. 3502 (and Amendment 2358 to the NDA) - Homebuyers Privacy Protection Act (All Sections) a bill to prohibit credit reporting agencies from providing a credit report not initiated by a consumer if the report is being provided on the basis that the consumer has had a credit inquiry regarding a home mortgage loan. This practice, known as producing a trigger lead, provides notice to other mortgage lenders that the consumer is seeking a mortgage loan. (Senate) Miscellaneous - Deposit Check Fraud - The prompt and reasonable reimbursements for community banks from the largest banks for fraudulently altered return checks, and the largest banks opening fraudulent accounts into which fraud items are being deposited, including - joint supervisory guidance addressed to the largest banks for their apparent management and compliance lapses, enhanced supervision, regulation and enforcement against the largest banks for CDD and CIP compliance (OCC)

CBAI Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau (CFPB) Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Sound Principles for Housing Government Sponsored Entity (GSE) Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Legitimate Bank Service Charges and Fees are not Exploitive and Junk Fees CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Realistic Perspective on Financial Inclusion CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks. Postal Banking Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking Public banking (i.e., publicly owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Federal Home Loan Banks in their Comprehensive Review Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. The results of the Comprehensive Review by the FHFA should not disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Rules and Implementation Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve - and must be closed. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. (House and Senate) Legislation and Regulation - S. 3502 (and Amendment 2358 to the NDA) - Homebuyers Privacy Protection Act (Senate) (All Sections) and H.R. 7297 - Trigger Leads Abatement Act (House) (All Sections) are bills to prohibit credit reporting agencies from providing a credit report not initiated by a consumer if the report is being provided on the basis that the consumer has had a credit inquiry regarding a home mortgage loan. This practice, known as producing a trigger lead, provides notice to other mortgage lenders that the consumer is seeking a mortgage loan. (Senate and House) H.R. 9303 and S. 4943 (All Sections) to protect consumers who are defrauded when they make payments (House and Senate) EGRPRA - Oral Comments During the EGRPRA Review concerning Anti Money Laundering, CTR and SAR reporting thresholds, Beneficial Ownership Interest reporting to FinCEN, and check fraud (FDIC, OCC, Federal Reserve) Letters - Comment Letter to the FHFA regarding Request for Input: Federal Home Loan Bank core mission and mission achievement (FHFA, FDIC, OCC, Federal Reserve) Comment Letter to the CFPB Regarding Proposed Rule - Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information [Debt] - Docket No. CFPB-2024-0023 and RIN 3170-AA54 (CFPB, FDIC, OCC, Federal Reserve) Action Alerts - Action Alert - Urge the Senate to pass S. 3502 (and Amendment 2358 to the NDA) - Homebuyers Privacy Protection Act (All Sections) a bill to prohibit credit reporting agencies from providing a credit report not initiated by a consumer if the report is being provided on the basis that the consumer has had a credit inquiry regarding a home mortgage loan. This practice, known as producing a trigger lead, provides notice to other mortgage lenders that the consumer is seeking a mortgage loan. (Senate) Miscellaneous - Deposit Check Fraud - The prompt and reasonable reimbursements for community banks from the largest banks for fraudulently altered return checks, and the largest banks opening fraudulent accounts into which fraud items are being deposited, including - joint supervisory guidance addressed to the largest banks for their apparent management and compliance lapses, enhanced supervision, regulation and enforcement against the largest banks for CDD and CIP compliance (OCC)

CBAI Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Current Issues, Opportunities and Concerns Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Reasonable Rules and Implementation Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. (House and Senate) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate and residences in small rural communities (House and Senate) S. 3502 and H.R. 7297 - Trigger Leads Abatement Act (All Sections) a bill to prohibit credit reporting agencies from providing a credit report not initiated by a consumer if the report is being provided on the basis that the consumer has had a credit inquiry regarding a home mortgage loan. This practice, known as producing a trigger lead, provides notice to other mortgage lenders that the consumer is seeking a mortgage loan. (Senate and House) Farm Bill - The Passage of a five-year Farm Bill with community bank priorities and without FCS expansion including higher limits on USDA guaranteed farm loans, quicker turnaround time for USDA Express loan approvals, and without and expansion of the Farm Credit System or their exemption from Dodd-Frank Section 1071 (House and Senate) Letters - CBAI-led joint trades letter with the Illinois Farm Bureau, Illinois Corn Growers Association, Illinois Soybean Growers, and the Grain and Feed Association of Illinois regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), which is legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Action Alerts - Action Alert - Urge Congress to Pass Farm Bill with community bank priorities and without FCS expansion including higher limits on USDA guaranteed farm loans, quicker turnaround time for USDA Express loan approvals, and without and expansion of the Farm Credit System or their exemption from Dodd-Frank Section 1071 (House) Miscellaneous - Community Reinvestment Act (CRA), transfer of beneficial ownership reporting requirements (BOI) to FinCEN, Small Business Data Collection (Dodd-Frank Section 1071), consumer access to financial records (Dodd-Frank Section 1033), credit unions, Farm Credit System, check fraud, and financial services/banking industry consolidation (Federal Reserve)

CBAI Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Current Issues, Opportunities and Concerns Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Reasonable Rules and Implementation Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. (House and Senate) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate and residences in small rural communities (House and Senate) Farm Bill - The Passage of a five-year Farm Bill with community bank priorities and without FCS expansion including higher limits on USDA guaranteed farm loans, quicker turnaround time for USDA Express loan approvals, and without and expansion of the Farm Credit System or their exemption from Dodd-Frank Section 1071 (House and Senate) Letters - CBAI-led joint trades letter with the Illinois Farm Bureau, Illinois Corn Growers Association, Illinois Soybean Growers, and the Grain and Feed Association of Illinois regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), which is legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Action Alerts - Action Alert - Urge Congress to Pass Farm Bill with community bank priorities and without FCS expansion including higher limits on USDA guaranteed farm loans, quicker turnaround time for USDA Express loan approvals, and without and expansion of the Farm Credit System or their exemption from Dodd-Frank Section 1071 (House) Miscellaneous - Community Reinvestment Act (CRA), transfer of beneficial ownership reporting requirements (BOI) to FinCEN, Small Business Data Collection (Dodd-Frank Section 1071), consumer access to financial records (Dodd-Frank Section 1033), credit unions, Farm Credit System, check fraud, and financial services/banking industry consolidation (Federal Reserve)

CBAI Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau (CFPB) Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks. SBA Direct Lending Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Reasonable Rules and Implementation Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished completely and expeditiously. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Harmful Climate Risk Regulations CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. (House and Senate) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate and residences in small rural communities (House and Senate) S. 1838 - Credit Card Competition Act of 2023 (All Sections) to amend the Electronic Fund Transfer Act to require the Board of Governors of the Federal Reserve System to prescribe regulations relating to network access and competition in credit card transactions (House) S.J.Res 32 - Joint Resolution nullifying the CFPBs Section 1071 - Small Business Data Collection Rule (House) S. 2860 - SAFER Banking Act (All Sections) to provide protections for federally regulated financial institutions that serve state-sanctioned marijuana businesses (House and Senate) Farm Bill - The Passage of a five-year Farm Bill with community bank priorities and without FCS expansion including higher limits on USDA guaranteed farm loans, quicker turnaround time for USDA Express loan approvals, and without and expansion of the Farm Credit System or their exemption from Dodd-Frank Section 1071 (House and Senate) Letters - Comment Letter to the Federal Reserve - Debit Card Interchange Fees and Routing requirements - Docket No. R-1818, RIN 7100-AG67 (Federal Reserve) CBAI-led joint trades letter with the Illinois Farm Bureau, Illinois Corn Growers Association, Illinois Soybean Growers, and the Grain and Feed Association of Illinois regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), which is legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Action Alerts - Action Alert - Urge Congress to Pass Farm Bill with community bank priorities and without FCS expansion including higher limits on USDA guaranteed farm loans, quicker turnaround time for USDA Express loan approvals, and without and expansion of the Farm Credit System or their exemption from Dodd-Frank Section 1071 (House) Miscellaneous - Deposit Check Fraud - The prompt and reasonable reimbursements for community banks from the largest banks for fraudulently altered return checks, and the largest banks opening fraudulent accounts into which fraud items are being deposited, including - joint supervisory guidance addressed to the largest banks for their apparent management and compliance lapses, enhanced supervision, regulation and enforcement against the largest banks for CDD and CIP compliance (House and Senate, OCC, Federal Reserve and FDIC) Community Reinvestment Act (CRA), transfer of beneficial ownership reporting requirements (BOI) to FinCEN, Small Business Data Collection (Dodd-Frank Section 1071), consumer access to financial records (Dodd-Frank Section 1033), credit unions, Farm Credit System, check fraud, and financial services/banking industry consolidation (Federal Reserve)

CBAI Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau (CFPB) Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Sound Principles for Housing Government Sponsored Entity (GSE) Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Legitimate Bank Service Charges and Fees are not Exploitive and Junk Fees CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Realistic Perspective on Financial Inclusion CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks. Postal Banking Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking Public banking (i.e., publicly owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Federal Home Loan Banks in their Comprehensive Review Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. The results of the Comprehensive Review by the FHFA should not disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Rules and Implementation Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve - and must be closed. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. (House and Senate) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate and residences in small rural communities (House and Senate) S. 3502 and H.R. 7297 - Trigger Leads Abatement Act (All Sections) a bill to prohibit credit reporting agencies from providing a credit report not initiated by a consumer if the report is being provided on the basis that the consumer has had a credit inquiry regarding a home mortgage loan. This practice, known as producing a trigger lead, provides notice to other mortgage lenders that the consumer is seeking a mortgage loan. (Senate and House) S. 1838 - Credit Card Competition Act of 2023 (All Sections) to amend the Electronic Fund Transfer Act to require the Board of Governors of the Federal Reserve System to prescribe regulations relating to network access and competition in credit card transactions (House) Letters - Comment Letter to the CFPB regarding Proposed Rule - Overdraft Lending: Very Large Financial Institutions - Docket No. CFPB-2024-0002 and RIN 3170-AA42 (CFPB) Comment Letter to the Federal Reserve - Debit Card Interchange Fees and Routing requirements - Docket No. R-1818, RIN 7100-AG67 (Federal Reserve) CBAI-led joint trades letter with the Illinois Farm Bureau, Illinois Corn Growers Association, Illinois Soybean Growers, and the Grain and Feed Association of Illinois regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), which is legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Action Alerts - None Miscellaneous - Residential mortgage Trigger Leads (CFPB) Deposit Check Fraud - The prompt and reasonable reimbursements for community banks from the largest banks for fraudulently altered return checks, and the largest banks opening fraudulent accounts into which fraud items are being deposited, including - joint supervisory guidance addressed to the largest banks for their apparent management and compliance lapses, enhanced supervision, regulation and enforcement against the largest banks for CDD and CIP compliance (House and Senate, OCC, Federal Reserve and FDIC) Community Reinvestment Act (CRA), transfer of beneficial ownership reporting requirements (BOI) to FinCEN, Small Business Data Collection (Dodd-Frank Section 1071), consumer access to financial records (Dodd-Frank Section 1033), credit unions, Farm Credit System, check fraud, and financial services/banking industry consolidation (Federal Reserve)

CBAI Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau (CFPB) Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states, is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for Housing Government Sponsored Entity (GSE) Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Responsible Bank Merger Activity New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Legitimate Bank Service Charges and Fees are not Exploitive and Junk Fees CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Realistic Perspective on Financial Inclusion CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks. SBA Direct Lending Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Postal Banking Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking Public banking (i.e., publicly owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Federal Home Loan Banks in their Comprehensive Review Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. The results of the Comprehensive Review by the FHFA should not disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Rules and Implementation Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished completely and expeditiously. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve - and must be closed. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Appropriate Regulations of Fintechs and Innovation in Financial Services Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Harmful Climate Risk Regulations CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. (House and Senate) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate and residences in small rural communities (House and Senate) S. 3502 and H.R. 7297 - Trigger Leads Abatement Act (All Sections) a bill to prohibit credit reporting agencies from providing a credit report not initiated by a consumer if the report is being provided on the basis that the consumer has had a credit inquiry regarding a home mortgage loan. This practice, known as producing a trigger lead, provides notice to other mortgage lenders that the consumer is seeking a mortgage loan. (Senate and House) S. 3638 - Close the Shadow Banking Loophole Act (All Sections) to prevent large companies from gaining access to the federal safety net and escaping federal oversight and supervision by the Federal Reserve (House and Senate) S. 1838 - Credit Card Competition Act of 2023 (All Sections) to amend the Electronic Fund Transfer Act to require the Board of Governors of the Federal Reserve System to prescribe regulations relating to network access and competition in credit card transactions (House) S.J.Res 32 - Joint Resolution nullifying the CFPBs Section 1071 - Small Business Data Collection Rule (House) S. 2860 - SAFER Banking Act (All Sections) to provide protections for federally regulated financial institutions that serve state-sanctioned marijuana businesses (House and Senate) Farm Bill - The Passage of a five-year Farm Bill with community bank priorities and without FCS expansion including higher limits on USDA guaranteed farm loans, quicker turnaround time for USDA Express loan approvals, and without and expansion of the Farm Credit System or their exemption from Dodd-Frank Section 1071 (House and Senate) Letters - Comment Letter to the CFPB regarding Proposed Rule - Overdraft Lending: Very Large Financial Institutions - Docket No. CFPB-2024-0002 and RIN 3170-AA42 (CFPB) Comment Letter to the OCC, Federal Reserve and FDIC - Regulatory Publication and Review Under Economic Growth and Regulatory Paperwork Reduction Act of 1996 (EGRPRA), Docket ID OCC-2023-0016, Federal Reserve Board Docket No. OP-1828, and FDIC - EGRPRA - specifically, tiered and appropriate regulations for community banks, closing the Industrial Loan Company loophole, favorable climate for de novo community bank formation (OCC, Federal Reserve and FDIC) Comment Letter to the Federal Reserve - Debit Card Interchange Fees and Routing requirements - Docket No. R-1818, RIN 7100-AG67 (Federal Reserve) CBAI-led joint trades letter with the Illinois Farm Bureau, Illinois Corn Growers Association, Illinois Soybean Growers, and the Grain and Feed Association of Illinois regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), which is legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Action Alerts - Action Alert - Urge Congress to Pass Farm Bill with community bank priorities and without FCS expansion including higher limits on USDA guaranteed farm loans, quicker turnaround time for USDA Express loan approvals, and without and expansion of the Farm Credit System or their exemption from Dodd-Frank Section 1071 (House) Miscellaneous - Residential mortgage Trigger Leads (CFPB) Deposit Check Fraud - The prompt and reasonable reimbursements for community banks from the largest banks for fraudulently altered return checks, and the largest banks opening fraudulent accounts into which fraud items are being deposited, including - joint supervisory guidance addressed to the largest banks for their apparent management and compliance lapses, enhanced supervision, regulation and enforcement against the largest banks for CDD and CIP compliance (House and Senate, OCC, Federal Reserve and FDIC) Federal Reserve balance sheet (Federal Reserve) Resignation of FDIC Chairman Martin Gruenberg (House) Stopping bank regulatory overreach (House, Senate and Federal Reserve) Community Reinvestment Act (CRA), transfer of beneficial ownership reporting requirements (BOI) to FinCEN, Small Business Data Collection (Dodd-Frank Section 1071), consumer access to financial records (Dodd-Frank Section 1033), credit unions, Farm Credit System, check fraud, and financial services/banking industry consolidation (Federal Reserve) Too-big-to-fail and stronger capital requirements for the largest banks (House)

CBAI Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Sound Principles for Housing Government Sponsored Entity (GSE) Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Federal Home Loan Banks in their Comprehensive Review Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. The results of the Comprehensive Review by the FHFA should not disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Rules and Implementation Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished completely and expeditiously. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Harmful Climate Risk Regulations CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. (House and Senate) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate and residences in small rural communities (House and Senate) S. 3502 and H.R. 7297 - Trigger Leads Abatement Act (All Sections) a bill to prohibit credit reporting agencies from providing a credit report not initiated by a consumer if the report is being provided on the basis that the consumer has had a credit inquiry regarding a home mortgage loan. This practice, known as producing a trigger lead, provides notice to other mortgage lenders that the consumer is seeking a mortgage loan. (Senate and House) S.J.Res 32 - Joint Resolution nullifying the CFPBs Section 1071 - Small Business Data Collection Rule (House) S. 2860 - SAFER Banking Act (All Sections) to provide protections for federally regulated financial institutions that serve state-sanctioned marijuana businesses (House and Senate) Farm Bill - The Passage of a five-year Farm Bill with community bank priorities and without FCS expansion including higher limits on USDA guaranteed farm loans, quicker turnaround time for USDA Express loan approvals, and without and expansion of the Farm Credit System or their exemption from Dodd-Frank Section 1071 (House and Senate) Letters - CBAI-led joint trades letter with the Illinois Farm Bureau, Illinois Corn Growers Association, Illinois Soybean Growers, and the Grain and Feed Association of Illinois regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), which is legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Action Alerts - Action Alert - Urge Congress to Pass Farm Bill with community bank priorities and without FCS expansion including higher limits on USDA guaranteed farm loans, quicker turnaround time for USDA Express loan approvals, and without and expansion of the Farm Credit System or their exemption from Dodd-Frank Section 1071 (House) Miscellaneous - Residential mortgage Trigger Leads (CFPB) Deposit Check Fraud - The prompt and reasonable reimbursements for community banks from the largest banks for fraudulently altered return checks, and the largest banks opening fraudulent accounts into which fraud items are being deposited, including - joint supervisory guidance addressed to the largest banks for their apparent management and compliance lapses, enhanced supervision, regulation and enforcement against the largest banks for CDD and CIP compliance (House and Senate, OCC, Federal Reserve and FDIC) Community Reinvestment Act (CRA), transfer of beneficial ownership reporting requirements (BOI) to FinCEN, Small Business Data Collection (Dodd-Frank Section 1071), consumer access to financial records (Dodd-Frank Section 1033), credit unions, Farm Credit System, check fraud, and financial services/banking industry consolidation (Federal Reserve)

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau (CFPB) Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states, is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for Housing Government Sponsored Entity (GSE) Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Responsible Bank Merger Activity New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Legitimate Bank Service Charges and Fees are not Exploitive and Junk Fees CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Realistic Perspective on Financial Inclusion CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks. SBA Direct Lending Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Postal Banking Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking Public banking (i.e., publicly owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Federal Home Loan Banks in their Comprehensive Review Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. The results of the Comprehensive Review by the FHFA should not disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Rules and Implementation Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished completely and expeditiously. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve - and must be closed. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Appropriate Regulations of Fintechs and Innovation in Financial Services Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Harmful Climate Risk Regulations CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. (House and Senate) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) S.J.Res 32 - Joint Resolution nullifying the CFPBs Section 1071 - Small Business Data Collection Rule (FDIC) S. 3638 - Close the Shadow Banking Loophole Act (All Sections) to prevent large companies from gaining access to the federal safety net and escaping federal oversight and supervision and (Senate) S. 3502 and H.R. 3502 - Trigger Leads Abatement Act (All Sections) a bill to prohibit credit reporting agencies from providing a credit report not initiated by a consumer if the report is being provided on the basis that the consumer has had a credit inquiry regarding a home mortgage loan. This practice, known as producing a trigger lead, provides notice to other mortgage lenders that the consumer is seeking a mortgage loan. (Senate and House) Farm Bill - The Passage of a five-year Farm Bill with Community Bank Priorities and without FCS Expansion including higher limits on USDA guaranteed farm loans, quicker turnaround time for USDA Express loan approvals, and without and expansion of the Farm Credit System or their exemption from Dodd-Frank Section 1071 (House and Senate) H.R. 4721 - Main Street Tax Certainty Act (All Sections) legislation to make permanent the tax deduction for qualified business income. (Under current law, the deduction expires after December 31, 2025.) (House) Letters - Comment Letter to the CFPB regarding Proposed Rule - Required Rulemaking on Personal Financial Data Rights - Docket ID No. CFPB-2023-0052 and RIN 3170-AA78 (FDIC) Comment Letter to the FDIC regarding guidelines for establishing standards for corporate governance and risk management - RIN 3064-AF94 (FDIC) CBAI-led joint trades letter with the Illinois Farm Bureau, Illinois Corn Growers Association, Illinois Soybean Growers, and the Grain and Feed Association of Illinois regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), which is legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Comment Letter to the CFPB regarding Proposed Rule - Fees for Instantly Declined Transactions - Docket ID No. CFPB-2024-0003 and RIN 3170-AB16 (CFPB) Letter to the OCC, Federal Reserve, and FDIC regarding Check Fraud - Prompt and reasonable reimbursements from the largest banks for fraudulently altered return checks (Fraud Returns), and the largest banks opening fraud accounts into which fraud items are being deposited, including - joint supervisory guidance addressed to the largest banks for their apparent management and compliance lapses, enhanced supervision, regulation and enforcement against the largest banks for CDD and CIP compliance (OCC, FDIC, Federal Reserve, House and Senate) Action Alerts - Action Alert - Support Closing the Industrial Loan Company (ILC) Loophole. Support legislation (S. 3538) Close the Shadow Banking Loophole Act (all sections) to prevent large companies from gaining access to the federal safety net and escaping federal oversight and supervision and (Senate) Action Alert - Urge Congress to Pass Farm Bill with Community Bank Priorities and without FCS Expansion including higher limits on USDA guaranteed farm loans, quicker turnaround time for USDA Express loan approvals, and without and expansion of the Farm Credit System or their exemption from Dodd-Frank Section 1071 (House and Senate) Miscellaneous - None

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau (CFPB) Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states, is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for Housing Government Sponsored Entity (GSE) Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Responsible Bank Merger Activity New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Legitimate Bank Service Charges and Fees are not Exploitive and Junk Fees CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Realistic Perspective on Financial Inclusion CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks. SBA Direct Lending Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Postal Banking Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking Public banking (i.e., publicly owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Federal Home Loan Banks in their Comprehensive Review Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. The results of the Comprehensive Review by the FHFA should not disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Rules and Implementation Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished completely and expeditiously. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve - and must be closed. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Appropriate Regulations of Fintechs and Innovation in Financial Services Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Harmful Climate Risk Regulations CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. (House and Senate) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) S.J.Res 32 - Joint Resolution nullifying the CFPBs Section 1071 - Small Business Data Collection Rule (FDIC) S. 3638 - Close the Shadow Banking Loophole Act (All Sections) to prevent large companies from gaining access to the federal safety net and escaping federal oversight and supervision and (Senate) S. 3502 and H.R. 3502 - Trigger Leads Abatement Act (All Sections) a bill to prohibit credit reporting agencies from providing a credit report not initiated by a consumer if the report is being provided on the basis that the consumer has had a credit inquiry regarding a home mortgage loan. This practice, known as producing a trigger lead, provides notice to other mortgage lenders that the consumer is seeking a mortgage loan. (Senate and House) Farm Bill - The Passage of a five-year Farm Bill with Community Bank Priorities and without FCS Expansion including higher limits on USDA guaranteed farm loans, quicker turnaround time for USDA Express loan approvals, and without and expansion of the Farm Credit System or their exemption from Dodd-Frank Section 1071 (House and Senate) H.R. 4721 - Main Street Tax Certainty Act (All Sections) legislation to make permanent the tax deduction for qualified business income. (Under current law, the deduction expires after December 31, 2025.) (House) Letters - Comment Letter to the CFPB regarding Proposed Rule - Required Rulemaking on Personal Financial Data Rights - Docket ID No. CFPB-2023-0052 and RIN 3170-AA78 (FDIC) Comment Letter to the FDIC regarding guidelines for establishing standards for corporate governance and risk management - RIN 3064-AF94 (FDIC) CBAI-led joint trades letter with the Illinois Farm Bureau, Illinois Corn Growers Association, Illinois Soybean Growers, and the Grain and Feed Association of Illinois regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), which is legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Comment Letter to the CFPB regarding Proposed Rule - Fees for Instantly Declined Transactions - Docket ID No. CFPB-2024-0003 and RIN 3170-AB16 (CFPB) Letter to the OCC, Federal Reserve, and FDIC regarding Check Fraud - Prompt and reasonable reimbursements from the largest banks for fraudulently altered return checks (Fraud Returns), and the largest banks opening fraud accounts into which fraud items are being deposited, including - joint supervisory guidance addressed to the largest banks for their apparent management and compliance lapses, enhanced supervision, regulation and enforcement against the largest banks for CDD and CIP compliance (OCC, FDIC, Federal Reserve, House and Senate) Action Alerts - Action Alert - Support Closing the Industrial Loan Company (ILC) Loophole. Support legislation (S. 3538) Close the Shadow Banking Loophole Act (all sections) to prevent large companies from gaining access to the federal safety net and escaping federal oversight and supervision and (Senate) Action Alert - Urge Congress to Pass Farm Bill with Community Bank Priorities and without FCS Expansion including higher limits on USDA guaranteed farm loans, quicker turnaround time for USDA Express loan approvals, and without and expansion of the Farm Credit System or their exemption from Dodd-Frank Section 1071 (House and Senate) Miscellaneous - None

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Sound Principles for Housing Government Sponsored Entity (GSE) Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Federal Home Loan Banks in their Comprehensive Review Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. The results of the Comprehensive Review by the FHFA should not disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Rules and Implementation Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished completely and expeditiously. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Harmful Climate Risk Regulations CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. (House and Senate) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) S.J.Res 32 - Joint Resolution nullifying the CFPBs Section 1071 - Small Business Data Collection Rule (FDIC) Farm Bill - The Passage of a five-year Farm Bill with Community Bank Priorities and without FCS Expansion including higher limits on USDA guaranteed farm loans, quicker turnaround time for USDA Express loan approvals, and without and expansion of the Farm Credit System or their exemption from Dodd-Frank Section 1071 (House and Senate) H.R. 4721 - Main Street Tax Certainty Act (All Sections) legislation to make permanent the tax deduction for qualified business income. (Under current law, the deduction expires after December 31, 2025.) (House) Letters - CBAI-led joint trades letter with the Illinois Farm Bureau, Illinois Corn Growers Association, Illinois Soybean Growers, and the Grain and Feed Association of Illinois regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), which is legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Letter to the OCC, Federal Reserve, and FDIC regarding Check Fraud - Prompt and reasonable reimbursements from the largest banks for fraudulently altered return checks (Fraud Returns), and the largest banks opening fraud accounts into which fraud items are being deposited, including - joint supervisory guidance addressed to the largest banks for their apparent management and compliance lapses, enhanced supervision, regulation and enforcement against the largest banks for CDD and CIP compliance (OCC, FDIC, Federal Reserve, House and Senate) Action Alerts - Action Alert - Urge Congress to Pass Farm Bill with Community Bank Priorities and without FCS Expansion including higher limits on USDA guaranteed farm loans, quicker turnaround time for USDA Express loan approvals, and without and expansion of the Farm Credit System or their exemption from Dodd-Frank Section 1071 (House and Senate) Miscellaneous - None

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Current Issues, Opportunities and Concerns Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Reasonable Rules and Implementation Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. (House and Senate) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) H.R. 4721 - Main Street Tax Certainty Act (All Sections) legislation to make permanent the tax deduction for qualified business income. (Under current law, the deduction expires after December 31, 2025.) (House) Letters - CBAI-led joint trades letter with the Illinois Farm Bureau, Illinois Corn Growers Association, Illinois Soybean Growers, and the Grain and Feed Association of Illinois regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), which is legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Action Alerts - None Miscellaneous - None

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau (CFPB) Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks. SBA Direct Lending Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Reasonable Rules and Implementation Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished completely and expeditiously. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Harmful Climate Risk Regulations CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. (House and Senate) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) S.J.Res 32 - Joint Resolution nullifying the CFPBs Section 1071 - Small Business Data Collection Rule (FDIC) H.R. 4721 - Main Street Tax Certainty Act (All Sections) legislation to make permanent the tax deduction for qualified business income. (Under current law, the deduction expires after December 31, 2025.) (House) Farm Bill - The Passage of a five-year Farm Bill with Community Bank Priorities and without FCS Expansion including higher limits on USDA guaranteed farm loans, quicker turnaround time for USDA Express loan approvals, and without and expansion of the Farm Credit System or their exemption from Dodd-Frank Section 1071 (House and Senate) Letters - CBAI-led joint trades letter with the Illinois Farm Bureau, Illinois Corn Growers Association, Illinois Soybean Growers, and the Grain and Feed Association of Illinois regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), which is legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Check Fraud - Prompt and reasonable reimbursements from the largest banks for fraudulently altered return checks (Fraud Returns), and the largest banks opening fraud accounts into which fraud items are being deposited, including - joint supervisory guidance addressed to the largest banks for their apparent management and compliance lapses, enhanced supervision, regulation and enforcement against the largest banks for CDD and CIP compliance (OCC, FDIC, Federal Reserve, House and Senate) Action Alerts - None Miscellaneous - None

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau (CFPB) Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Sound Principles for Housing Government Sponsored Entity (GSE) Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Legitimate Bank Service Charges and Fees are not Exploitive and Junk Fees CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Realistic Perspective on Financial Inclusion CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks. Postal Banking Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking Public banking (i.e., publicly owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Federal Home Loan Banks in their Comprehensive Review Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. The results of the Comprehensive Review by the FHFA should not disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Rules and Implementation Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve - and must be closed. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. (House and Senate) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) S. 3502 and H.R. 3502 - Trigger Leads Abatement Act (All Sections) a bill to prohibit credit reporting agencies from providing a credit report not initiated by a consumer if the report is being provided on the basis that the consumer has had a credit inquiry regarding a home mortgage loan. This practice, known as producing a trigger lead, provides notice to other mortgage lenders that the consumer is seeking a mortgage loan. (Senate and House) Letters - Comment Letter to the CFPB regarding Proposed Rule - Required Rulemaking on Personal Financial Data Rights - Docket ID No. CFPB-2023-0052 and RIN 3170-AA78 (FDIC) CBAI-led joint trades letter with the Illinois Farm Bureau, Illinois Corn Growers Association, Illinois Soybean Growers, and the Grain and Feed Association of Illinois regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), which is legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Comment Letter to the CFPB regarding Proposed Rule - Fees for Instantly Declined Transactions - Docket ID No. CFPB-2024-0003 and RIN 3170-AB16 (CFPB) Letter to the OCC, Federal Reserve, and FDIC regarding Check Fraud - Prompt and reasonable reimbursements from the largest banks for fraudulently altered return checks (Fraud Returns), and the largest banks opening fraud accounts into which fraud items are being deposited, including - joint supervisory guidance addressed to the largest banks for their apparent management and compliance lapses, enhanced supervision, regulation and enforcement against the largest banks for CDD and CIP compliance (OCC, FDIC, Federal Reserve, House and Senate) Action Alerts - None Miscellaneous - None

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau (CFPB) Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks. SBA Direct Lending Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Reasonable Rules and Implementation Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished completely and expeditiously. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Harmful Climate Risk Regulations CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. (House and Senate) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) S.J.Res 32 - Joint Resolution nullifying the CFPBs Section 1071 - Small Business Data Collection Rule (House and President) S. 3356 - Postal Police Reform Act of 2023 (Both Sections), legislation that would modify the role and duties of the postal police and inspectors - in our opinion to better combat the theft of mail and help address the issue of bank check fraud (Senate) S. 1838. And H.R. 3881 - Credit Card Competition Act of 2023 (all Sections), legislation that will amend the Electronic Fund Transfer Act to require the Board of Governors of the Federal Reserve System to prescribe regulations relating to network competition in credit card transactions (House and Senate) Letters - Joint Trades letter with the Illinois Farm Bureau regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Action Alerts - None Miscellaneous - Reimbursements from the largest banks for fraudulently altered return checks (Fraud Returns) including - the regulators intervention, providing dedicated resources to lodge complaints, Joint Regulatory Supervisory Guidance, dedicated points of contact at the largest banks, Community Bankers Association of Illinois member guidance with directions on filing complaints to the federal regulators, and the enhanced supervision of the largest banks for CDD and CIP compliance (OCC, FDIC, Federal Reserve) Direct Deposit Diversion Fraud and the nexus between this type of fraud and reimbursements for fraudulently altered return checks (Fraud Returns) (Federal Reserve) Economic Roundtable where bank capital rules were discussed among other topics identified elsewhere in this LDR (House)

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Sound Principles for Housing Government Sponsored Entity (GSE) Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Federal Home Loan Banks in their Comprehensive Review Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. The results of the Comprehensive Review by the FHFA should not disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Rules and Implementation Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished completely and expeditiously. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Harmful Climate Risk Regulations CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. (House and Senate) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) S.J.Res 32 - Joint Resolution nullifying the CFPBs Section 1071 - Small Business Data Collection Rule (House and President) S. 3356 - Postal Police Reform Act of 2023 (Both Sections), legislation that would modify the role and duties of the postal police and inspectors - in our opinion to better combat the theft of mail and help address the issue of bank check fraud (Senate) Letters - Joint Trades letter with the Illinois Farm Bureau regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Action Alerts - None Miscellaneous - Reimbursements from the largest banks for fraudulently altered return checks (Fraud Returns) including - the regulators intervention, providing dedicated resources to lodge complaints, Joint Regulatory Supervisory Guidance, dedicated points of contact at the largest banks, Community Bankers Association of Illinois member guidance with directions on filing complaints to the federal regulators, and the enhanced supervision of the largest banks for CDD and CIP compliance (OCC, FDIC, Federal Reserve) Direct Deposit Diversion Fraud and the nexus between this type of fraud and reimbursements for fraudulently altered return checks (Fraud Returns) (Federal Reserve)

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Current Issues, Opportunities and Concerns Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Reasonable Rules and Implementation Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. (House and Senate) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Letters - Joint Trades letter with the Illinois Farm Bureau regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Action Alerts - None Miscellaneous - None

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau (CFPB) Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states, is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for Housing Government Sponsored Entity (GSE) Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Responsible Bank Merger Activity New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Legitimate Bank Service Charges and Fees are not Exploitive and Junk Fees CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Realistic Perspective on Financial Inclusion CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks. SBA Direct Lending Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Postal Banking Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking Public banking (i.e., publicly owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Federal Home Loan Banks in their Comprehensive Review Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. The results of the Comprehensive Review by the FHFA should not disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Rules and Implementation Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished completely and expeditiously. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve - and must be closed. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Appropriate Regulations of Fintechs and Innovation in Financial Services Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Harmful Climate Risk Regulations CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. (House and Senate) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) S.J.Res 32 - Joint Resolution nullifying the CFPBs Section 1071 - Small Business Data Collection Rule (House and President) S. 3356 - Postal Police Reform Act of 2023 (Both Sections), legislation that would modify the role and duties of the postal police and inspectors - in our opinion to better combat the theft of mail and help address the issue of bank check fraud (Senate) S. 1838. And H.R. 3881 - Credit Card Competition Act of 2023 (all Sections), legislation that will amend the Electronic Fund Transfer Act to require the Board of Governors of the Federal Reserve System to prescribe regulations relating to network competition in credit card transactions (House and Senate) Letters - Comment Letter to the CFPB regarding Proposed Rule - Required Rulemaking on Personal Financial Data Rights - Docket ID No. CFPB-2023-0052 and RIN 3170-AA78 Joint Trades letter with the Illinois Farm Bureau regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Action Alerts - None Miscellaneous - Reimbursements from the largest banks for fraudulently altered return checks (Fraud Returns) including - the regulators intervention, providing dedicated resources to lodge complaints, Joint Regulatory Supervisory Guidance, dedicated points of contact at the largest banks, Community Bankers Association of Illinois member guidance with directions on filing complaints to the federal regulators, and the enhanced supervision of the largest banks for CDD and CIP compliance (OCC, FDIC, Federal Reserve) Direct Deposit Diversion Fraud and the nexus between this type of fraud and reimbursements for fraudulently altered return checks (Fraud Returns) (Federal Reserve) Responsible review of the FDIC and deposit insurance limits and finalizing the exemption for community banks from paying a special assessment in connection with the failures of SVB (CA) and SB (NY) (House and Senate)

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau (CFPB) Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states, is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for Housing Government Sponsored Entity (GSE) Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Responsible Bank Merger Activity New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Legitimate Bank Service Charges and Fees are not Exploitive and Junk Fees CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Realistic Perspective on Financial Inclusion CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks. SBA Direct Lending Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Postal Banking Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking Public banking (i.e., publicly owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Federal Home Loan Banks in their Comprehensive Review Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. The results of the Comprehensive Review by the FHFA should not disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Rules and Implementation Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished completely and expeditiously. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve - and must be closed. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Appropriate Regulations of Fintechs and Innovation in Financial Services Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Harmful Climate Risk Regulations CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. (House and Senate) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) S.J.Res 32 - Joint Resolution nullifying the CFPBs Section 1071 - Small Business Data Collection Rule (House and President) S. 3356 - Postal Police Reform Act of 2023 (Both Sections), legislation that would modify the role and duties of the postal police and inspectors - in our opinion to better combat the theft of mail and help address the issue of bank check fraud (Senate) S. 1838. And H.R. 3881 - Credit Card Competition Act of 2023 (all Sections), legislation that will amend the Electronic Fund Transfer Act to require the Board of Governors of the Federal Reserve System to prescribe regulations relating to network competition in credit card transactions (House and Senate) Letters - Comment Letter to the CFPB regarding Proposed Rule - Required Rulemaking on Personal Financial Data Rights - Docket ID No. CFPB-2023-0052 and RIN 3170-AA78 Joint Trades letter with the Illinois Farm Bureau regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Action Alerts - None Miscellaneous - Reimbursements from the largest banks for fraudulently altered return checks (Fraud Returns) including - the regulators intervention, providing dedicated resources to lodge complaints, Joint Regulatory Supervisory Guidance, dedicated points of contact at the largest banks, Community Bankers Association of Illinois member guidance with directions on filing complaints to the federal regulators, and the enhanced supervision of the largest banks for CDD and CIP compliance (OCC, FDIC, Federal Reserve) Direct Deposit Diversion Fraud and the nexus between this type of fraud and reimbursements for fraudulently altered return checks (Fraud Returns) (Federal Reserve) Responsible review of the FDIC and deposit insurance limits and finalizing the exemption for community banks from paying a special assessment in connection with the failures of SVB (CA) and SB (NY) (House and Senate)

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Current Issues, Opportunities and Concerns Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Reasonable Rules and Implementation Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. (House and Senate) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Letters - Joint Trades letter with the Illinois Farm Bureau regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Action Alerts - None Miscellaneous - None

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Current Issues, Opportunities and Concerns Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Reasonable Rules and Implementation Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. (House and Senate, Federal Reserve, FDIC, OCC) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Letters - Joint Trades letter with the Illinois Farm Bureau regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Action Alerts - None Miscellaneous - None

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau (CFPB) Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks. SBA Direct Lending Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Reasonable Rules and Implementation Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished completely and expeditiously. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Harmful Climate Risk Regulations CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. (House and Senate, Federal Reserve, FDIC, OCC) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) S. 1838. And H.R. 3881 - Credit Card Competition Act of 2023 (all Sections), legislation that will amend the Electronic Fund Transfer Act to require the Board of Governors of the Federal Reserve System to prescribe regulations relating to network competition in credit card transactions (House and Senate) Senate Small Business Committee markup of legislation that would include curbing the Administrations plan to expand the role of financial technology firms (non-bank lenders) in providing government-backed (SBA) small-business loans Letters - Joint Trades letter with the Illinois Farm Bureau regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Action Alerts - None Miscellaneous - Reimbursements from the largest banks for fraudulently altered return checks (Fraud Returns) including - the regulators intervention, providing dedicated resources to lodge complaints, Joint Regulatory Supervisory Guidance, dedicated points of contact at the largest banks, Community Bankers Association of Illinois member guidance with directions on filing complaints to the federal regulators, and the enhanced supervision of the largest banks for CDD and CIP compliance (House, Senate, OCC, FDIC, Federal Reserve) Direct Deposit Diversion Fraud and the nexus between this type of fraud and reimbursements for fraudulently altered return checks (Fraud Returns) (Federal Reserve) Professor Arthur Wilmarths Linkedin post and American Banker Bank Think article opposing PayPals plan to issue stablecoin (House and Senate)

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Current Issues, Opportunities and Concerns Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Reasonable Rules and Implementation Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. (House and Senate, Federal Reserve, FDIC, OCC) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Letters - Joint Trades letter with the Illinois Farm Bureau regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Action Alerts - None Miscellaneous - None

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau (CFPB) Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states, is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for Housing Government Sponsored Entity (GSE) Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Responsible Bank Merger Activity New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Legitimate Bank Service Charges and Fees are not Exploitive and Junk Fees CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Realistic Perspective on Financial Inclusion CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks. SBA Direct Lending Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Postal Banking Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking Public banking (i.e., publicly owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Federal Home Loan Banks in their Comprehensive Review Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. The results of the Comprehensive Review by the FHFA should not disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Rules and Implementation Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished completely and expeditiously. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve - and must be closed. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Appropriate Regulations of Fintechs and Innovation in Financial Services Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Harmful Climate Risk Regulations CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. (House and Senate, Federal Reserve, OCC, FDIC) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) S. 1838. And H.R. 3881 - Credit Card Competition Act of 2023 (all Sections), legislation that will amend the Electronic Fund Transfer Act to require the Board of Governors of the Federal Reserve System to prescribe regulations relating to network competition in credit card transactions (House and Senate) Senate Small Business Committee markup of legislation that would include curbing the Administrations plan to expand the role of financial technology firms (non-bank lenders) in providing government-backed (SBA) small-business loans Letters - Comment Letter to the FDIC regarding Proposed Rule - Special Assessment Pursuant to Systemic Risk Determination - RIN 3064-AF93 (FDIC) Joint Trades letter with the Illinois Farm Bureau regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Action Alerts - Action Alert regarding Urging the FDIC to Finalize and Exemption for Community Banks from Paying a Special Assessment in Connection with the Failures of SVB and SBNY (FDIC) Miscellaneous - Reimbursements from the largest banks for fraudulently altered return checks (Fraud Returns) including - the regulators intervention, providing dedicated resources to lodge complaints, Joint Regulatory Supervisory Guidance, dedicated points of contact at the largest banks, Community Bankers Association of Illinois member guidance with directions on filing complaints to the federal regulators, and the enhanced supervision of the largest banks for CDD and CIP compliance (House, Senate, OCC, FDIC, Federal Reserve) Direct Deposit Diversion Fraud and the nexus between this type of fraud and reimbursements for fraudulently altered return checks (Fraud Returns) (Federal Reserve) Professor Arthur Wilmarths Linkedin post and American Banker Bank Think article opposing PayPals plan to issue stablecoin (House and Senate)

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Sound Principles for Housing Government Sponsored Entity (GSE) Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Federal Home Loan Banks in their Comprehensive Review Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. The results of the Comprehensive Review by the FHFA should not disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Rules and Implementation Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished completely and expeditiously. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Harmful Climate Risk Regulations CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. (House and Senate, Federal Reserve, FDIC, OCC) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Letters - Joint Trades letter with the Illinois Farm Bureau regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Action Alerts - None Miscellaneous - Reimbursements from the largest banks for fraudulently altered return checks (Fraud Returns) including - the regulators intervention, providing dedicated resources to lodge complaints, Joint Regulatory Supervisory Guidance, dedicated points of contact at the largest banks, Community Bankers Association of Illinois member guidance with directions on filing complaints to the federal regulators, and the enhanced supervision of the largest banks for CDD and CIP compliance (House, Senate, OCC, FDIC, Federal Reserve) Direct Deposit Diversion Fraud and the nexus between this type of fraud and reimbursements for fraudulently altered return checks (Fraud Returns) (Federal Reserve) Professor Arthur Wilmarths Linkedin post and American Banker Bank Think article opposing PayPals plan to issue stablecoin (House and Senate)

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau (CFPB) Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states, is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for Housing Government Sponsored Entity (GSE) Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Responsible Bank Merger Activity New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Legitimate Bank Service Charges and Fees are not Exploitive and Junk Fees CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Realistic Perspective on Financial Inclusion CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks. SBA Direct Lending Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Postal Banking Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking Public banking (i.e., publicly owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Federal Home Loan Banks in their Comprehensive Review Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. The results of the Comprehensive Review by the FHFA should not disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Rules and Implementation Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished completely and expeditiously. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve - and must be closed. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Appropriate Regulations of Fintechs and Innovation in Financial Services Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Harmful Climate Risk Regulations CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. (House and Senate, Federal Reserve, OCC, FDIC) Legislation and Regulation - H.R. 3139 and S. 2371- ACRE Act of 2023 (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) S. 1838. And H.R. 3881 - Credit Card Competition Act of 2023 (all Sections), legislation that will amend the Electronic Fund Transfer Act to require the Board of Governors of the Federal Reserve System to prescribe regulations relating to network competition in credit card transactions (House and Senate) Senate Small Business Committee markup of legislation that would include curbing the Administrations plan to expand the role of financial technology firms (non-bank lenders) in providing government-backed (SBA) small-business loans Letters - Comment Letter to the FDIC regarding Proposed Rule - Special Assessment Pursuant to Systemic Risk Determination - RIN 3064-AF93 (FDIC) Joint Trades letter with the Illinois Farm Bureau regarding H.R. 3139 and S. 2371- The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House and Senate) Action Alerts - Action Alert regarding Urging the FDIC to Finalize and Exemption for Community Banks from Paying a Special Assessment in Connection with the Failures of SVB and SBNY (FDIC) Miscellaneous - Reimbursements from the largest banks for fraudulently altered return checks (Fraud Returns) including - the regulators intervention, providing dedicated resources to lodge complaints, Joint Regulatory Supervisory Guidance, dedicated points of contact at the largest banks, Community Bankers Association of Illinois member guidance with directions on filing complaints to the federal regulators, and the enhanced supervision of the largest banks for CDD and CIP compliance (House, Senate, OCC, FDIC, Federal Reserve) Direct Deposit Diversion Fraud and the nexus between this type of fraud and reimbursements for fraudulently altered return checks (Fraud Returns) (Federal Reserve) Professor Arthur Wilmarths Linkedin post and American Banker Bank Think article opposing PayPals plan to issue stablecoin (House and Senate)

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau (CFPB) Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states, is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for Housing Government Sponsored Entity (GSE) Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Responsible Bank Merger Activity New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Legitimate Bank Service Charges and Fees are not Exploitive and Junk Fees CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Realistic Perspective on Financial Inclusion CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks. SBA Direct Lending Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Postal Banking Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking Public banking (i.e., publicly owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Federal Home Loan Banks in their Comprehensive Review Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. The results of the Comprehensive Review by the FHFA should not disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Rules and Implementation Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished completely and expeditiously. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve - and must be closed. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Appropriate Regulations of Fintechs and Innovation in Financial Services Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Harmful Climate Risk Regulations CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. (House and Senate, Federal Reserve, OCC, FDIC, CFPB) Legislation and Regulation - H.J.Res. 50 - A resolution to disapprove of the CFPBs Small Business Loan Application Data Collection Rule (House and Senate) H.R. 3139 - ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House) S. 1838./H.R. 3881 - Credit Card Competition Act of 2023 (all Sections), legislation that will amend the Electronic Fund Transfer Act to require the Board of Governors of the Federal Reserve system to prescribe regulations relating to network competition in credit card transactions (House and Senate) Letters - Comment Letter to the CFPB regarding Proposed Rule - Credit Card Penalty Fees (Regulation Z); Docket No. CFPB2023-0010 and RIN 3170-AB15 (CFPB) Joint Trades letter regarding H.R. 3139 - The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House) Action Alerts - Action Alert to members of congress regarding a Joint Resolution (H.J.Res 50) to Nullify the CFPBs Section 1071 Rule (House and Senate) Miscellaneous - Reimbursements from the largest banks for fraudulently altered return checks (Fraud Returns) including - the regulators intervention, providing dedicated resources to lodge complaints, Joint Regulatory Supervisory Guidance, dedicated points of contact at the largest banks, Community Bankers Association of Illinois member guidance with directions on filing complaints to the federal regulators, and the enhanced supervision of the largest banks for CDD and CIP compliance. (House, Senate, OCC, FDIC, Federal Reserve) Reimbursing the FDICs Deposit Insurance Fund (DIF) for losses incurred from the insurance of uninsured depositors at the failed Silicon Valley Bank (CA) and Signature Bank (NY) (FDIC) Supervisory Guidance on charging overdraft fees for authorize positive, settle negative transactions (FDIC) House Financial Services Committee hearing on stable coins and their 1-to-1 backing by reserves of highly liquid assets (House)

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Sound Principles for Housing Government Sponsored Entity (GSE) Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Federal Home Loan Banks in their Comprehensive Review Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. The results of the Comprehensive Review by the FHFA should not disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Rules and Implementation Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished completely and expeditiously. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Harmful Climate Risk Regulations CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. (House and Senate, Federal Reserve, FDIC, OCC, CFPB) Legislation and Regulation - H.J.Res. 50 - A resolution to disapprove of the CFPBs Small Business Loan Application Data Collection Rule (House and Senate) H.R. 3139 - ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House) Letters - Joint Trades letter regarding H.R. 3139 - The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House) Action Alerts - Action Alert to members of congress regarding a Joint Resolution (H.J.Res 50) to Nullify the CFPBs Section 1071 Rule (House and Senate) Miscellaneous - Reimbursements from the largest banks for fraudulently altered return checks (Fraud Returns) including - the regulators intervention, providing dedicated resources to lodge complaints, Joint Regulatory Supervisory Guidance, dedicated points of contact at the largest banks, Community Bankers Association of Illinois member guidance with directions on filing complaints to the federal regulators, and the enhanced supervision of the largest banks for CDD and CIP compliance. (House, Senate, OCC, FDIC, Federal Reserve) House Financial Services Committee hearing on stable coins and their 1-to-1 backing by reserves of highly liquid assets (House)

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau (CFPB) Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks. SBA Direct Lending Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Reasonable Rules and Implementation Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished completely and expeditiously. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Harmful Climate Risk Regulations CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. (House and Senate, Federal Reserve, FDIC, OCC, CFPB) Legislation and Regulation - H.J.Res. 50 - A resolution to disapprove of the CFPBs Small Business Loan Application Data Collection Rule (House and Senate) H.R. 3139 - ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House) Letters - Joint Trades letter regarding H.R. 3139 - The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House) Action Alerts - Action Alert to members of congress regarding a Joint Resolution (H.J.Res 50) to Nullify the CFPBs Section 1071 Rule (House and Senate) Miscellaneous - Reimbursements from the largest banks for fraudulently altered return checks (Fraud Returns) including - the regulators intervention, providing dedicated resources to lodge complaints, Joint Regulatory Supervisory Guidance, dedicated points of contact at the largest banks, Community Bankers Association of Illinois member guidance with directions on filing complaints to the federal regulators, and the enhanced supervision of the largest banks for CDD and CIP compliance (House, Senate, OCC, FDIC, Federal Reserve) House Financial Services Committee hearing on stable coins and their 1-to-1 backing by reserves of highly liquid assets (House)

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Current Issues, Opportunities and Concerns Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Reasonable Rules and Implementation Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. (House and Senate, Federal Reserve, FDIC, OCC, CFPB) Legislation and Regulation - H.R. 3139 - ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House) Letters - Joint Trades letter regarding H.R. 3139 - The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House) Action Alerts - None Miscellaneous - House Financial Services Committee hearing on stable coins and their 1-to-1 backing by reserves of highly liquid assets (House)

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau (CFPB) Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states, is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for Housing Government Sponsored Entity (GSE) Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Responsible Bank Merger Activity New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Legitimate Bank Service Charges and Fees are not Exploitive and Junk Fees CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Realistic Perspective on Financial Inclusion CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks. SBA Direct Lending Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Postal Banking Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking Public banking (i.e., publicly owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Federal Home Loan Banks in their Comprehensive Review Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. The results of the Comprehensive Review by the FHFA should not disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Rules and Implementation Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished completely and expeditiously. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve - and must be closed. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Appropriate Regulations of Fintechs and Innovation in Financial Services Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Harmful Climate Risk Regulations CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. (House and Senate, Federal Reserve, OCC, FDIC, CFPB) Legislation and Regulation - H.J.Res. 50 - A resolution to disapprove of the CFPBs Small Business Loan Application Data Collection Rule (House and Senate) H.R. 3139 - ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House) S. 1838./H.R. 3881 - Credit Card Competition Act of 2023 (all Sections), legislation that will amend the Electronic Fund Transfer Act to require the Board of Governors of the Federal Reserve system to prescribe regulations relating to network competition in credit card transactions (House and Senate) Letters - Comment Letter to the CFPB regarding Proposed Rule - Credit Card Penalty Fees (Regulation Z); Docket No. CFPB2023-0010 and RIN 3170-AB15 (CFPB) Joint Trades letter regarding H.R. 3139 - The ACRE Act (Access to Credit for our Rural Economy Act) (All Sections), legislation that will exclude from the gross income of certain financial lending institutions, for income tax purposes, interest received on loans secured by rural or agricultural real estate (House) Action Alerts - Action Alert to members of congress regarding a Joint Resolution (H.J.Res 50) to Nullify the CFPBs Section 1071 Rule (House and Senate) Miscellaneous - Reimbursements from the largest banks for fraudulently altered return checks (Fraud Returns) including - the regulators intervention, providing dedicated resources to lodge complaints, Joint Regulatory Supervisory Guidance, dedicated points of contact at the largest banks, Community Bankers Association of Illinois member guidance with directions on filing complaints to the federal regulators, and the enhanced supervision of the largest banks for CDD and CIP compliance. (House, Senate, OCC, FDIC, Federal Reserve) Reimbursing the FDICs Deposit Insurance Fund (DIF) for losses incurred from the insurance of uninsured depositors at the failed Silicon Valley Bank (CA) and Signature Bank (NY) (FDIC) Supervisory Guidance on charging overdraft fees for authorize positive, settle negative transactions (FDIC) House Financial Services Committee hearing on stable coins and their 1-to-1 backing by reserves of highly liquid assets (House)

CBAI 2023 Federal Policy Priorities - The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulations, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation, and systemic risk. Based on these guiding principles, CBAI has identified the following 2023 Federal Legislative and Regulatory Policy Priorities, which if implemented, will help community banks thrive and better serve their customers and communities. Traditional Issues, Opportunities and Concerns Additional Meaningful Regulatory Relief for Community Banks The importance of community banks cannot be overstated, and they serve their customers and communities honestly and with respect. CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau (CFPB) Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Sound Principles for Housing Government Sponsored Entity (GSE) Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Financial Transaction Tax Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Current Issues, Opportunities and Concerns Bank Regulators Involvement in Resolving Reimbursement for Fraudulently Altered Returned Checks CBAIs member community banks have been experiencing a pernicious and growing problem with reimbursements for fraudulently altered checks drawn on their customers accounts. The problem can be accurately summarized as being caused by the nations largest banks and credit union, where these checks were deposited in fraudulent accounts, which is harming community banks and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI has urged the regulators to get involved and address this problem. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Completely-Insure) Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts TBTF The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. TBTNCI The recent failures of two large banks in early 2023, and the FDIC insuring 100% of their uninsured deposits, have raised new concerns about deposit insurance and have prompted calls for broader FDIC reforms. If systemically important financial institutions (SIFIs) cause losses to the Deposit Insurance Fund (DIF) then SIFIs should be responsible for reimbursing the DIF for those losses. Legitimate Bank Service Charges and Fees are not Exploitive and Junk Fees CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Realistic Perspective on Financial Inclusion CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks. Postal Banking Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking Public banking (i.e., publicly owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), and Stablecoins The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. Federal Home Loan Banks in their Comprehensive Review Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. The results of the Comprehensive Review by the FHFA should not disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Rules and Implementation Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Modernizing the Community Reinvestment Act (CRA) (OCC, Federal Reserve and FDIC) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve - and must be closed. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. IRS Reporting Plan The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. (House and Senate, Federal Reserve, OCC, FDIC, CFPB) Legislation and Regulation - S. 1838./H.R. 3881 - Credit Card Competition Act of 2023 (all Sections), legislation that will amend the Electronic Fund Transfer Act to require the Board of Governors of the Federal Reserve system to prescribe regulations relating to network competition in credit card transactions (House and Senate) Letters - Comment Letter to the CFPB regarding Proposed Rule - Credit Card Penalty Fees (Regulation Z); Docket No. CFPB2023-0010 and RIN 3170-AB15 (CFPB) Action Alerts - None Miscellaneous - Reimbursements from the largest banks for fraudulently altered return checks (Fraud Returns) including - the regulators intervention, providing dedicated resources to lodge complaints, Joint Regulatory Supervisory Guidance, dedicated points of contact at the largest banks, Community Bankers Association of Illinois member guidance with directions on filing complaints to the federal regulators, and the enhanced supervision of the largest banks for CDD and CIP compliance. (House, Senate, OCC, FDIC, Federal Reserve) Supervisory Guidance on charging overdraft fees for authorize positive, settle negative transactions (FDIC) House Financial Services Committee hearing on stable coins and their 1-to-1 backing by reserves of highly liquid assets (House)

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Community Bank Positions on New and Emerging Issues - Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress, and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Climate Risks (Administration, Congress, and the Agencies) CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail outs, and subsequent recession were caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised, or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate, Federal Reserve, OCC) Legislation and Regulation - None Letters - Comment Letter to the CFPB regarding - the ICBAs Trial Disclosure Application, Docket No. CFPB-2023-0016 (CFPB) Action Alerts - Action Alert titled Urge CFPB to Approve TRID Improvement Proposal which is regarding the testing and adoption of a proposal to improve mortgage disclosures under TILA-RESPA Integrated Disclosure (TRID) rules (CFPB) Miscellaneous - None

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve - and must be closed. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states, is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Community Bank Positions on New and Emerging Issues - Leadership for Bank Regulatory Agencies (Administration, Congress, and the Agencies) Recent nominees have held extreme views on the banking system and financial services and their nominations have increasingly caused unproductive political wrangling. Nominees should be qualified, hold reasonable positions, be willing to work collegially and cooperatively with colleagues and counterparts, serve the best interests of the banking and financial system and economy, and clearly understand the vital importance of and support community banks. Fintechs and Innovation in Financial Services (Congress and the Agencies) Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Special Purpose National Banks (SPNBs) (OCC) SPNBs, raise many concerns. They cannot have the advantages of a bank charter with limited requirements, regulations, and liability. Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress, and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. SBA Direct Lending (Congress) Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Financial Inclusion (Congress and the Agencies) CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking (Congress) Public banking (i.e., publicly owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Current Expected Credit Loss Model (CECL) (FASB and the Agencies) Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Nonsufficient Funds (Overdraft) Policies and Practices (OCC and the CFPB) CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Climate Risks (Administration, Congress, and the Agencies) CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. Bank Merger Activity (Congress and the Agencies) New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate, Federal Reserve, OCC) Legislation and Regulation - None Letters - Comment Letter to the SBA regarding Proposed Rule - Small Business Lending Company (SBLC) Moratorium Rescission and Removal of Requirement for a Loan Authorization; Docket Number SBA-2022-0013 and RIN 3425-AH92 (SBA) Comment Letter to the CFPB regarding SBREFA - Dodd-Frank Section 1033 Rulemaking - Personal Financial Data Sharing (CFPB) Comment Letter to FinCEN regarding Proposed Rule - Beneficial Ownership Information Access and Safeguards, and Use of FinCEN Identifiers for Entities - Docket Number FINCEN-2021-0005 and RIN 1506-AB49/AB50 (FinCEN) Comment Letter to the CFPB regarding - the ICBAs Trial Disclosure Application, Docket No. CFPB-2023-0016 (CFPB) Comment Letter to the FHFA regarding - The FHLBank System at 100: Focusing on the Future (Comprehensive Review) (FHFA) Action Alerts - Action Alert titled Urge CFPB to Approve TRID Improvement Proposal which is regarding the testing and adoption of a proposal to improve mortgage disclosures under TILA-RESPA Integrated Disclosure (TRID) rules (CFPB) Miscellaneous - Letter to the President about nominations for the FDIC Board - Dodd-Frank Act requirements that one member of the Board shall have state supervisory experience (President, Senate) Letter to the OCC, Federal Reserve, and the FDIC about delays in receiving reimbursement for Fraudulently Altered Return Checks (OCC, Federal Reserve, FDIC, House) Letter to the Federal Reserve about their denial of Custodia Banks application for Federal Reserve membership (Federal Reserve) Letter to House Financial Services Committee (HFSC) and Senate Banking Committee leadership requesting oversight hearings on the National Credit Union Administration (NCUA) (House and Senate) Legitimate bank service charges and fees are not, as characterized by the CFPB, exploitive, unfair, unlawful - Junk Fees (House, Senate, OCC) FHFA Listening Session (Second Round) - FHLBank System at 100: Focusing on the Future regarding the comprehensive review of the FHLBs including their role and potential policy changes (FHFA) The responsibility for the reimbursing the FDICs Deposit Insurance Fund (DIF) resulting from the failures of Silicon Valley Bank and Signature Bank and the FDICs insuring 100% of those failed banks deposits (House) Regarding the failures of Silicon Valley Bank and Signature Bank, policymakers did not follow the Dodd-Frank Act in using the Orderly Liquidation Authority (OLA) and the Orderly Liquidation Fund (OLF) but instead relied on the Systemic Risk Exception (SRE) to resolve these failed banks and insure 100% of the failed banks deposits (House)

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve and must be closed. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Community Bank Positions on New and Emerging Issues - Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress, and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Financial Inclusion (Congress and the Agencies) CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Postal Banking (Congress) Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking (Congress) Public banking (i.e., publicly owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Nonsufficient Funds (Overdraft) Policies and Practices (OCC and the CFPB) CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised, or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate, Federal Reserve, OCC) Legislation and Regulations - None Letters - Comment Letter to the CFPB regarding SBREFA - Dodd-Frank Section 1033 Rulemaking - Personal Financial Data Sharing (CFPB) Comment Letter to the CFPB regarding - the ICBAs Trial Disclosure Application, Docket No. CFPB-2023-0016 (CFPB) Comment Letter to the FHFA regarding - The FHLBank System at 100: Focusing on the Future (Comprehensive Review) (FHFA) Action Alerts - Action Alert titled Urge CFPB to Approve TRID Improvement Proposal which is regarding the testing and adoption of a proposal to improve mortgage disclosures under TILA-RESPA Integrated Disclosure (TRID) rules (CFPB) Miscellaneous - Letter to the OCC, Federal Reserve, and the FDIC about delays in receiving reimbursement for Fraudulently Altered Return Checks (OCC, Federal Reserve, FDIC, House) Letter to House Financial Services Committee (HFSC) and Senate Banking Committee leadership requesting oversight hearings on the National Credit Union Administration (NCUA) (House and Senate) Legitimate bank service charges and fees are not, as characterized by the CFPB, exploitive, unfair, unlawful - Junk Fees (House, Senate, OCC) FHFA Listening Session (Second Round) - FHLBank System at 100: Focusing on the Future regarding the comprehensive review of the FHLBs including their role and potential policy changes (FHFA) The responsibility for the reimbursing the FDICs Deposit Insurance Fund (DIF) resulting from the failures of Silicon Valley Bank and Signature Bank and the FDICs insuring 100% of those failed banks deposits (House) Regarding the failures of Silicon Valley Bank and Signature Bank, policymakers did not follow the Dodd-Frank Act in using the Orderly Liquidation Authority (OLA) and the Orderly Liquidation Fund (OLF) but instead relied on the Systemic Risk Exception (SRE) to resolve these failed banks and insure 100% of the failed banks deposits (House)

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail outs, and subsequent recession were caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised, or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate, Federal Reserve, OCC) Legislation and Regulation - None Letters - Comment Letter to the FHFA regarding - The FHLBank System at 100: Focusing on the Future (Comprehensive Review) (FHFA) Action Alerts - None Miscellaneous - FHFA Listening Session (Second Round) - FHLBank System at 100: Focusing on the Future regarding the comprehensive review of the FHLBs including their role and potential policy changes (FHFA)

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve - and must be closed. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states, is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Community Bank Positions on New and Emerging Issues - Leadership for Bank Regulatory Agencies (Administration, Congress, and the Agencies) Recent nominees have held extreme views on the banking system and financial services and their nominations have increasingly caused unproductive political wrangling. Nominees should be qualified, hold reasonable positions, be willing to work collegially and cooperatively with colleagues and counterparts, serve the best interests of the banking and financial system and economy, and clearly understand the vital importance of and support community banks. Fintechs and Innovation in Financial Services (Congress and the Agencies) Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Special Purpose National Banks (SPNBs) (OCC) SPNBs, raise many concerns. They cannot have the advantages of a bank charter with limited requirements, regulations, and liability. Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress, and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. SBA Direct Lending (Congress) Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Financial Inclusion (Congress and the Agencies) CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking (Congress) Public banking (i.e., publicly owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Current Expected Credit Loss Model (CECL) (FASB and the Agencies) Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Nonsufficient Funds (Overdraft) Policies and Practices (OCC and the CFPB) CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Climate Risks (Administration, Congress, and the Agencies) CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. Bank Merger Activity (Congress and the Agencies) New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate, Federal Reserve, OCC) Legislation and Regulation - None Letters - Comment Letter to the SBA regarding Proposed Rule - Small Business Lending Company (SBLC) Moratorium Rescission and Removal of Requirement for a Loan Authorization; Docket Number SBA-2022-0013 and RIN 3425-AH92 (SBA) Comment Letter to the CFPB regarding SBREFA - Dodd-Frank Section 1033 Rulemaking - Personal Financial Data Sharing (CFPB) Comment Letter to FinCEN regarding Proposed Rule - Beneficial Ownership Information Access and Safeguards, and Use of FinCEN Identifiers for Entities - Docket Number FINCEN-2021-0005 and RIN 1506-AB49/AB50 (FinCEN) Comment Letter to the CFPB regarding - the ICBAs Trial Disclosure Application, Docket No. CFPB-2023-0016 (CFPB) Comment Letter to the FHFA regarding - The FHLBank System at 100: Focusing on the Future (Comprehensive Review) (FHFA) Action Alerts - Action Alert titled Urge CFPB to Approve TRID Improvement Proposal which is regarding the testing and adoption of a proposal to improve mortgage disclosures under TILA-RESPA Integrated Disclosure (TRID) rules (CFPB) Miscellaneous - Letter to the President about nominations for the FDIC Board - Dodd-Frank Act requirements that one member of the Board shall have state supervisory experience (President, Senate) Letter to the OCC, Federal Reserve, and the FDIC about delays in receiving reimbursement for Fraudulently Altered Return Checks (OCC, Federal Reserve, FDIC, House) Letter to the Federal Reserve about their denial of Custodia Banks application for Federal Reserve membership (Federal Reserve) Letter to House Financial Services Committee (HFSC) and Senate Banking Committee leadership requesting oversight hearings on the National Credit Union Administration (NCUA) (House and Senate) Legitimate bank service charges and fees are not, as characterized by the CFPB, exploitive, unfair, unlawful - Junk Fees (House, Senate, OCC) FHFA Listening Session (Second Round) - FHLBank System at 100: Focusing on the Future regarding the comprehensive review of the FHLBs including their role and potential policy changes (FHFA) The responsibility for the reimbursing the FDICs Deposit Insurance Fund (DIF) resulting from the failures of Silicon Valley Bank and Signature Bank and the FDICs insuring 100% of those failed banks deposits (House) Regarding the failures of Silicon Valley Bank and Signature Bank, policymakers did not follow the Dodd-Frank Act in using the Orderly Liquidation Authority (OLA) and the Orderly Liquidation Fund (OLF) but instead relied on the Systemic Risk Exception (SRE) to resolve these failed banks and insure 100% of the failed banks deposits (House)

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and the economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Community Bank Positions on New and Emerging Issues - Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small businesses. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress, and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raise serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. SBA Direct Lending (Congress) Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Climate Risks (Administration, Congress, and the Agencies) CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporate material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised, or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate, Federal Reserve, OCC) Legislation and Regulation - Comment Letter to the SBA regarding Proposed Rule - Small Business Lending Company (SBLC) Moratorium Rescission and Removal of Requirement for a Loan Authorization; Docket Number SBA-2022-0013 and RIN 3425-AH92 (SBA) Comment Letter to the CFPB regarding SBREFA - Dodd-Frank Section 1033 Rulemaking - Personal Financial Data Sharing (CFPB) Comment Letter to FinCEN regarding Proposed Rule - Beneficial Ownership Information Access and Safeguards, and Use of FinCEN Identifiers for Entities - Docket Number FINCEN-2021-0005 and RIN 1506-AB49/AB50 (FinCEN) Letters - None Action Alerts - None Miscellaneous - Letter to the OCC, Federal Reserve, and the FDIC about delays in receiving reimbursement for Fraudulently Altered Return Checks (OCC, Federal Reserve, FDIC, House) The responsibility for the reimbursing the FDICs Deposit Insurance Fund (DIF) resulting from the failures of Silicon Valley Bank and Signature Bank and the FDICs insuring 100% of those failed banks deposits (House) Regarding the failures of Silicon Valley Bank and Signature Bank, policymakers did not follow the Dodd-Frank Act in using the Orderly Liquidation Authority (OLA) and the Orderly Liquidation Fund (OLF) but instead relied on the Systemic Risk Exception (SRE) to resolve these failed banks and insure 100% of the failed banks deposits (House)

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve and must be closed. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Community Bank Positions on New and Emerging Issues - Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress, and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Financial Inclusion (Congress and the Agencies) CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Postal Banking (Congress) Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking (Congress) Public banking (i.e., publicly owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Nonsufficient Funds (Overdraft) Policies and Practices (OCC and the CFPB) CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include including returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised, or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate, Federal Reserve) Legislation and Regulations - H.R. 8874 - the Credit Card Competition Act of 2022 (all sections) which is legislation to overhaul the payments system (House) S. 910 - The SAFE Banking Act in the Senate (all sections) which permits the banking of cannabis related businesses in states where it is legal (Senate) Letters - Comment Letter to the FHFA regarding FHLBank System at 100: Focusing on the Future - the comprehensive review of the FHLBs including their role and potential policy changes (FHFA, Federal Reserve, OCC, FDIC, House) Action Alerts - Action Alert titled Help Defend the FHLBs! which is regarding the FHFAs request for written comments regarding the future role and functions of the FHLBs (FHFA) Miscellaneous - FHFA Listening Session - FHLBank System at 100: Focusing on the Future regarding the comprehensive review of the FHLBs including their role and potential policy changes (FHFA, Federal Reserve, OCC, FDIC) Federal Reserve regarding a variety of issues including - CBDC/Digital Assets, trade area within the modernization of the CRA, Fed supervised banks and requirements regarding crypto currency, fintech partnerships, fraudulent return items, CFPB and the Administrations rhetoric about bank so called junk fees, and regulators advocacy for the banks they are responsible for regulating to ensure their safety and soundness (Federal Reserve) Letter to the Administration (President Biden) and the CFPB (Director Chopra) regarding their rhetoric about bank service charges and fees and their characterization of them as junk fees (Administration/President, CFPB, House)

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Community Bank Positions on New and Emerging Issues - Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress, and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. SBA Direct Lending (Congress) Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Climate Risks (Administration, Congress, and the Agencies) CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporating material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised, or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate, Federal Reserve) Legislation and Regulation - H.R. 8874 - the Credit Card Competition Act of 2022 (all sections) which is legislation to overhaul the payments system (House) S. 910 - The SAFE Banking Act in the Senate (all sections) which permits the banking of cannabis related businesses in states where it is legal (Senate) Letters - None Action Alerts - None Miscellaneous - Federal Reserve regarding a variety of issues including - CBDC/Digital Assets, trade area within the modernization of the CRA, Fed supervised banks and requirements regarding crypto currency, fintech partnerships, fraudulent return items, CFPB and the Administrations rhetoric about bank so called junk fees, and regulators advocacy for the banks they are responsible for regulating to ensure their safety and soundness (Federal Reserve)

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve - and must be closed. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Community Bank Positions on New and Emerging Issues - Leadership for Bank Regulatory Agencies (Administration, Congress, and the Agencies) Recent nominees have held extreme views on the banking system and financial services and their nominations have increasingly caused unproductive political wrangling. Nominees should be qualified, hold reasonable positions, be willing to work collegially and cooperatively with colleagues and counterparts, serve the best interests of the banking and financial system and economy, and clearly understand the vital importance of and support community banks. Fintechs and Innovation in Financial Services (Congress and the Agencies) Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Special Purpose National Banks (SPNBs) (OCC) SPNBs, raise many concerns. They cannot have the advantages of a bank charter with limited requirements, regulations, and liability. Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress, and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. SBA Direct Lending (Congress) Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Financial Inclusion (Congress and the Agencies) CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking (Congress) Public banking (i.e., publicly owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Current Expected Credit Loss Model (CECL) (FASB and the Agencies) Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Nonsufficient Funds (Overdraft) Policies and Practices (OCC and the CFPB) CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include including returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Climate Risks (Administration, Congress, and the Agencies) CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporating material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. Bank Merger Activity (Congress and the Agencies) New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate, Federal Reserve) Legislation and Regulation - H.R. 8874 - the Credit Card Competition Act of 2022 (all sections) which is legislation to overhaul the payments system (House) S. 910 - The SAFE Banking Act in the Senate (all sections) which permits the banking of cannabis related businesses in states where it is legal (Senate) H.R. 5912 - Close the ILC Loophole Act (all sections) which is legislation to reform the regulation of industrial loan companies (ILCs) and their parent companies to provide for consolidated federal supervision (House) S. 5189 - Close the Shadow Banking Loophole Act (all sections) which is legislation to reform the regulation of industrial loan companies (ILCs) and their parent companies to provide for consolidated federal supervision (Senate) Letters - Comment Letter to the FDIC regarding Proposed Policy Statement on Prudent Commercial Real Estate Loan Accommodations and Workouts - RIN 3064-ZA33 (FDIC) Comment Letter to the FHFA regarding FHLBank System at 100: Focusing on the Future - the comprehensive review of the FHLBs including their role and potential policy changes (FHFA, Federal Reserve, OCC, FDIC, House) Action Alerts - Action Alert titled Help Defend the FHLBs! which is regarding the FHFAs request for written comments regarding the future role and functions of the FHLBs (FHFA) Miscellaneous - FHFA Listening Session - FHLBank System at 100: Focusing on the Future regarding the comprehensive review of the FHLBs including their role and potential policy changes (FHFA, Federal Reserve, OCC, FDIC) FHFA regarding the Net Tangible Capital issue that would impact members ability to obtain new or renew existing FHLB advances (FHFA, Federal Reserve, OCC, FDIC, Senate) Federal Reserve regarding a variety of issues including - CBDC/Digital Assets, trade area within the modernization of the CRA, Fed supervised banks and requirements regarding crypto currency, fintech partnerships, fraudulent return items, CFPB and the Administrations rhetoric about bank so-called junk fees, and regulators advocacy for the banks they are responsible for regulating to ensure their safety and soundness (Federal Reserve) Letter to the Administration (President Biden) and the CFPB (Director Chopra) regarding their rhetoric about bank service charges and fees and their characterization of them as junk fees (Administration/President, CFPB, House) Letter regarding a members continuing to serve on House Financial Services Committee (House)

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised, or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate, Federal Reserve) Legislation and Regulation - None Letters - Comment Letter to the FHFA regarding FHLBank System at 100: Focusing on the Future - the comprehensive review of the FHLBs including their role and potential policy changes (FHFA, Federal Reserve, OCC, FDIC, House) Action Alerts - Action Alert regarding Help Defend the FHLBs! in conjunction with FHFAs request for written comments regarding the future role and functions of the FHLBs (FHFA) Miscellaneous - FHFA Listening Session - FHLBank System at 100: Focusing on the Future regarding the comprehensive review of the FHLBs including their role and potential policy changes (FHFA, Federal Reserve, OCC, FDIC) Federal Reserve regarding a variety of issues including - CBDC/Digital Assets, trade area within the modernization of the CRA, Fed supervised banks and requirements regarding crypto currency, fintech partnerships, fraudulent return items, CFPB and the Administrations rhetoric about bank so called junk fees, and regulators advocacy for the banks they are responsible for regulating to ensure their safety and soundness (Federal Reserve)

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve - and must be closed. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Community Bank Positions on New and Emerging Issues - Leadership for Bank Regulatory Agencies (Administration, Congress, and the Agencies) Recent nominees have held extreme views on the banking system and financial services and their nominations have increasingly caused unproductive political wrangling. Nominees should be qualified, hold reasonable positions, be willing to work collegially and cooperatively with colleagues and counterparts, serve the best interests of the banking and financial system and economy, and clearly understand the vital importance of and support community banks. Fintechs and Innovation in Financial Services (Congress and the Agencies) Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Special Purpose National Banks (SPNBs) (OCC) SPNBs, raise many concerns. They cannot have the advantages of a bank charter with limited requirements, regulations, and liability. Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress, and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. SBA Direct Lending (Congress) Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Financial Inclusion (Congress and the Agencies) CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking (Congress) Public banking (i.e., publicly owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Current Expected Credit Loss Model (CECL) (FASB and the Agencies) Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Nonsufficient Funds (Overdraft) Policies and Practices (OCC and the CFPB) CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include including returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Climate Risks (Administration, Congress, and the Agencies) CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporating material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. Bank Merger Activity (Congress and the Agencies) New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate, Federal Reserve) Legislation and Regulation - H.R. 8874 - the Credit Card Competition Act of 2022 (all sections) which is legislation to overhaul the payments system (House) S. 910 - The SAFE Banking Act in the Senate (all sections) which permits the banking of cannabis related businesses in states where it is legal (Senate) H.R. 5912 - Close the ILC Loophole Act (all sections) which is legislation to reform the regulation of industrial loan companies (ILCs) and their parent companies to provide for consolidated federal supervision (House) S. 5189 - Close the Shadow Banking Loophole Act (all sections) which is legislation to reform the regulation of industrial loan companies (ILCs) and their parent companies to provide for consolidated federal supervision (Senate) Letters - Comment Letter to the FDIC regarding Proposed Policy Statement on Prudent Commercial Real Estate Loan Accommodations and Workouts - RIN 3064-ZA33 (FDIC) Comment Letter to the FHFA regarding FHLBank System at 100: Focusing on the Future - the comprehensive review of the FHLBs including their role and potential policy changes (FHFA, Federal Reserve, OCC, FDIC, House) Action Alerts - Action Alert titled Help Defend the FHLBs! which is regarding the FHFAs request for written comments regarding the future role and functions of the FHLBs (FHFA) Miscellaneous - FHFA Listening Session - FHLBank System at 100: Focusing on the Future regarding the comprehensive review of the FHLBs including their role and potential policy changes (FHFA, Federal Reserve, OCC, FDIC) FHFA regarding the Net Tangible Capital issue that would impact members ability to obtain new or renew existing FHLB advances (FHFA, Federal Reserve, OCC, FDIC, Senate) Federal Reserve regarding a variety of issues including - CBDC/Digital Assets, trade area within the modernization of the CRA, Fed supervised banks and requirements regarding crypto currency, fintech partnerships, fraudulent return items, CFPB and the Administrations rhetoric about bank so-called junk fees, and regulators advocacy for the banks they are responsible for regulating to ensure their safety and soundness (Federal Reserve) Letter to the Administration (President Biden) and the CFPB (Director Chopra) regarding their rhetoric about bank service charges and fees and their characterization of them as junk fees (Administration/President, CFPB, House) Letter regarding a members continuing to serve on House Financial Services Committee (House)

(House and Senate, Federal Reserve) CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Community Bank Positions on New and Emerging Issues - Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress, and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements falls disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Climate Risks (Administration, Congress, and the Agencies) CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporating material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised, or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate, Federal Reserve) Legislation and Regulation - S. 910 - The SAFE Banking Act in the Senate (all sections) which permits the banking of cannabis related businesses in states where it is legal (Senate) Letters - None Action Alerts - None Miscellaneous - Federal Reserve regarding a variety of issues including - CBDC/Digital Assets, trade area within the modernization of the CRA, Fed supervised banks and requirements regarding crypto currency, fintech partnerships, fraudulent return items, CFPB and the Administrations rhetoric about bank so called junk fees, and regulators advocacy for the banks they are responsible for regulating to ensure their safety and soundness (Federal Reserve)

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate, FDIC, OCC) Legislation and Regulation - Comment Letter to the Federal Reserve, FDIC and the OCC regarding Joint Notice of Proposed Rulemaking; Request for Comment on Community Reinvestment Act - Office of Comptroller of the Currency, Docker ID OCC-2022-0002 and RIN 1557-AF15; Federal Deposit Insurance Corporation, RIN 3064-AF81; Federal Reserve, Docket No. R-1769 and RIN 7100-AG-29 (Federal Reserve, FDIC, OCC and House) Letters - None Action Alerts - None Miscellaneous - None

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve, and must be closed. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Community Bank Positions on New and Emerging Issues - Leadership for Bank Regulatory Agencies (Administration, Congress, and the Agencies) Recent nominees have held extreme views on the banking system and financial services and their nominations have increasingly caused unproductive political wrangling. Nominees should be qualified, hold reasonable positions, be willing to work collegially and cooperatively with colleagues and counterparts, serve the best interests of the banking and financial system and economy, and clearly understand the vital importance of and support community banks. Fintechs and Innovation in Financial Services (Congress and the Agencies) Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Special Purpose National Banks (SPNBs) (OCC) SPNBs, raise many concerns. They cannot have the advantages of a bank charter with limited requirements, regulations, and liability. Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. SBA Direct Lending (Congress) Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Financial Inclusion (Congress and the Agencies) CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking (Congress) Public banking (i.e., publicly-owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Current Expected Credit Loss Model (CECL) (FASB and the Agencies) Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements fall disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Nonsufficient Funds (Overdraft) Policies and Practices (OCC and the CFPB) CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include including returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Climate Risks (Administration, Congress, and the Agencies) CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporating material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. Bank Merger Activity (Congress and the Agencies) New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate, FDIC, OCC) Legislation and Regulation - H.R. 1996 - The SAFE Banking Act in the Senate (all sections) which permits the banking of cannabis related businesses in states where it is legal (Senate) HR 4277 - the Overdraft Protection Act of 2021(all sections) which limits banks ability to charge overdraft fees (House) H.R. 5912 - Close the ILC Loophole Act (all sections) which is legislation to reform the regulation of industrial loan companies (ILCs) and their parent companies to provide for consolidated federal supervision (House) Letters - Comment Letter to the SEC regarding Enhancement and Standardization of Climate-Related Disclosures for Investors - 87 Fed. Reg. 21,334 (April 11, 2022) (SEC) Comment Letter to the Federal Reserve, FDIC and the OCC regarding Joint Notice of Proposed Rulemaking; Request for Comment on Community Reinvestment Act - Office of Comptroller of the Currency, Docker ID OCC-2022-0002 and RIN 1557-AF15; Federal Deposit Insurance Corporation, RIN 3064-AF81; Federal Reserve, Docket No. R-1769 and RIN 7100-AG-29 (Federal Reserve, FDIC, OCC and House) Comment Letter to the Department of the Treasury regarding Request for Comments - Ensuring Responsible Development of Digital Assets (Treasury) Comment Letter to the FDIC regarding Notice of Public Rulemaking - Assessments, Revised Deposit Insurance Assessment Rates - RIN 3064-AF83 (FDIC) Action Alerts - Action Alert regarding: FDICs Notice of Proposed Rulemaking to Increase Deposit Insurance Assessments (FDIC) Miscellaneous - Debit Interchange (Reg II) regulations (Senate) Proposed stablecoin legislation (House) Check fraud and return items/recovery (Federal Reserve, FDIC and OCC) Overdraft and NSF fees in general and particularly representment (Federal Reserve, FDIC and OCC)

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Community Bank Positions on New and Emerging Issues - Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate, FDIC, OCC) Legislation and Regulation - None Letters - Comment Letter to the Federal Reserve, FDIC and the OCC regarding Joint Notice of Proposed Rulemaking; Request for Comment on Community Reinvestment Act - Office of Comptroller of the Currency, Docker ID OCC-2022-0002 and RIN 1557-AF15; Federal Deposit Insurance Corporation, RIN 3064-AF81; Federal Reserve, Docket No. R-1769 and RIN 7100-AG-29 (Federal Reserve, FDIC, OCC and House) Action Alerts - None Miscellaneous - None

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve, and must be closed. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Community Bank Positions on New and Emerging Issues - Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Financial Inclusion (Congress and the Agencies) CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Postal Banking (Congress) Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking (Congress) Public banking (i.e., publicly-owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Nonsufficient Funds (Overdraft) Policies and Practices (OCC and the CFPB) CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include including returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate, FDIC, OCC) Legislation and Regulations - H.R. 1996 - The SAFE Banking Act in the Senate (all sections) which permits the banking of cannabis related businesses in states where it is legal (Senate) HR 4277 - the Overdraft Protection Act of 2021(all sections) which limits banks ability to charge overdraft fees (House) Letters - Comment Letter to the Federal Reserve, FDIC and the OCC regarding Joint Notice of Proposed Rulemaking; Request for Comment on Community Reinvestment Act - Office of Comptroller of the Currency, Docker ID OCC-2022-0002 and RIN 1557-AF15; Federal Deposit Insurance Corporation, RIN 3064-AF81; Federal Reserve, Docket No. R-1769 and RIN 7100-AG-29 (Federal Reserve, FDIC, OCC and House) Comment Letter to the Department of the Treasury regarding Request for Comments - Ensuring Responsible Development of Digital Assets (Treasury) Action Alerts - None Miscellaneous - Debit Interchange (Reg II) regulations (Senate) Proposed stablecoin legislation (House) Check fraud and return items/recovery (Federal Reserve, FDIC and OCC) Overdraft and NSF fees in general and particularly representment (Federal Reserve, FDIC and OCC)

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve, and must be closed. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Community Bank Positions on New and Emerging Issues - Leadership for Bank Regulatory Agencies (Administration, Congress, and the Agencies) Recent nominees have held extreme views on the banking system and financial services and their nominations have increasingly caused unproductive political wrangling. Nominees should be qualified, hold reasonable positions, be willing to work collegially and cooperatively with colleagues and counterparts, serve the best interests of the banking and financial system and economy, and clearly understand the vital importance of and support community banks. Fintechs and Innovation in Financial Services (Congress and the Agencies) Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Special Purpose National Banks (SPNBs) (OCC) SPNBs, raise many concerns. They cannot have the advantages of a bank charter with limited requirements, regulations, and liability. Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. SBA Direct Lending (Congress) Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Financial Inclusion (Congress and the Agencies) CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking (Congress) Public banking (i.e., publicly-owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Current Expected Credit Loss Model (CECL) (FASB and the Agencies) Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements fall disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Nonsufficient Funds (Overdraft) Policies and Practices (OCC and the CFPB) CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include including returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Climate Risks (Administration, Congress, and the Agencies) CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporating material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. Bank Merger Activity (Congress and the Agencies) New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate, FDIC, OCC) Legislation and Regulation - H.R. 1996 - The SAFE Banking Act in the Senate (all sections) which permits the banking of cannabis related businesses in states where it is legal (Senate) HR 4277 - the Overdraft Protection Act of 2021(all sections) which limits banks ability to charge overdraft fees (House) H.R. 5912 - Close the ILC Loophole Act (all sections) which is legislation to reform the regulation of industrial loan companies (ILCs) and their parent companies to provide for consolidated federal supervision (House) Letters - Comment Letter to the SEC regarding Enhancement and Standardization of Climate-Related Disclosures for Investors - 87 Fed. Reg. 21,334 (April 11, 2022) (SEC) Comment Letter to the Federal Reserve, FDIC and the OCC regarding Joint Notice of Proposed Rulemaking; Request for Comment on Community Reinvestment Act - Office of Comptroller of the Currency, Docker ID OCC-2022-0002 and RIN 1557-AF15; Federal Deposit Insurance Corporation, RIN 3064-AF81; Federal Reserve, Docket No. R-1769 and RIN 7100-AG-29 (Federal Reserve, FDIC, OCC and House) Comment Letter to the Department of the Treasury regarding Request for Comments - Ensuring Responsible Development of Digital Assets (Treasury) Comment Letter to the FDIC regarding Notice of Public Rulemaking - Assessments, Revised Deposit Insurance Assessment Rates - RIN 3064-AF83 (FDIC) Action Alerts - Action Alert regarding: FDICs Notice of Proposed Rulemaking to Increase Deposit Insurance Assessments (FDIC) Miscellaneous - Debit Interchange (Reg II) regulations (Senate) Proposed stablecoin legislation (House) Check fraud and return items/recovery (Federal Reserve, FDIC and OCC) Overdraft and NSF fees in general and particularly representment (Federal Reserve, FDIC and OCC)

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Community Bank Positions on New and Emerging Issues - Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements fall disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Climate Risks (Administration, Congress, and the Agencies) CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporating material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate, FDIC and OCC) Legislation and Regulation - H.R. 1996 - The SAFE Banking Act in the Senate (all sections) which permits the banking of cannabis related businesses in states where it is legal (Senate) Letters - Comment Letter to the Federal Reserve, FDIC and the OCC regarding Joint Notice of Proposed Rulemaking; Request for Comment on Community Reinvestment Act - Office of Comptroller of the Currency, Docker ID OCC-2022-0002 and RIN 1557-AF15; Federal Deposit Insurance Corporation, RIN 3064-AF81; Federal Reserve, Docket No. R-1769 and RIN 7100-AG-29 (Federal Reserve, FDIC,OCC and House) Action Alerts - None Miscellaneous - None

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve, and must be closed. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Community Bank Positions on New and Emerging Issues - Leadership for Bank Regulatory Agencies (Administration, Congress, and the Agencies) Recent nominees have held extreme views on the banking system and financial services and their nominations have increasingly caused unproductive political wrangling. Nominees should be qualified, hold reasonable positions, be willing to work collegially and cooperatively with colleagues and counterparts, serve the best interests of the banking and financial system and economy, and clearly understand the vital importance of and support community banks. Fintechs and Innovation in Financial Services (Congress and the Agencies) Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Special Purpose National Banks (SPNBs) (OCC) SPNBs, raise many concerns. They cannot have the advantages of a bank charter with limited requirements, regulations, and liability. Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. SBA Direct Lending (Congress) Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Financial Inclusion (Congress and the Agencies) CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking (Congress) Public banking (i.e., publicly-owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Current Expected Credit Loss Model (CECL) (FASB and the Agencies) Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements fall disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Nonsufficient Funds (Overdraft) Policies and Practices (OCC and the CFPB) CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include including returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Climate Risks (Administration, Congress, and the Agencies) CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporating material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. Bank Merger Activity (Congress and the Agencies) New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and FDIC) Legislation and Regulation - H.R. 5912 - Close the ILC Loophole Act (all sections) which is legislation to reform the regulation of industrial loan companies (ILCs) and their parent companies to provide for consolidated federal supervision (House) H.R. 4421 - America COMPETES Act of 2022 (in conference committee/reconciliation) H.R. 1996 - The SAFE Banking Act which permits the banking of cannabis related businesses in states where it is legal (House and Senate) H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) H.R. 7768 - Farm Credit Administration Independence Authority Act (all sections) which is legislation to exempt the Farm Credit System from being regulated by the CFPB and from compliance with Section 1071 of the Dodd-Frank Act - small business data collection (House) H.R. 2543 - Federal Reserve Racial and Economic Equity Act - Amendment to include H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) Letters - Comment Letter to the Federal Reserve System regarding: Supplemental Notice and request for Comments, Guidelines for Evaluating Account and Service Requests - Docket No. OP-1747 (Federal Reserve) Comment Letter to the FDIC regarding: Statement of Principles for Climate-Related Financial Risk Management for Large Financial Institutions - RIN 3064-ZA32 (FDIC) Comment Letter to the Federal Reserve regarding: Money and Payments: The Digital Dollar in the Age of Digital Transformation (Federal Reserve) Comment Letter to the FDIC regarding: Guidelines for Appeals of Material Supervisory Determinations - RIN 3064-ZA20 (FDIC) Action Alerts - Action Alert regarding: Expanded Credit Union Powers / H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) Miscellaneous - Comment Letter to the CFPB about Fees Imposed by Providers of Financial Products or Services (FDIC and House) Application to CFPBs regulatory sandbox (CFPB) Comment Letter to the Federal Reserve about Money and Payments: The Digital Dollar in the Age of Digital Transformation (House)

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Community Bank Positions on New and Emerging Issues - Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House) Legislation and Regulation - H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) H.R. 2543 - Federal Reserve Racial and Economic Equity Act - Amendment to include H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) Letters - None Action Alerts - Action Alert regarding: Expanded Credit Union Powers / H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) Miscellaneous - None

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve, and must be closed. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Community Bank Positions on New and Emerging Issues - Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Financial Inclusion (Congress and the Agencies) CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Postal Banking (Congress) Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking (Congress) Public banking (i.e., publicly-owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Nonsufficient Funds (Overdraft) Policies and Practices (OCC and the CFPB) CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include including returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House) Legislation and Regulations - H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) H.R. 2543 - Federal Reserve Racial and Economic Equity Act - Amendment to include H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) Letters - Comment Letter to the Federal Reserve - Money and Payments: The Digital Dollar in the Age of Digital Transformation (Federal Reserve) Action Alerts - Action Alert regarding: Expanded Credit Union Powers / H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) Miscellaneous - Comment Letter to the CFPB about Fees Imposed by Providers of Financial Products or Services (FDIC and House) Application to CFPBs regulatory sandbox (CFPB) Comment Letter to the Federal Reserve about Money and Payments: The Digital Dollar in the Age of Digital Transformation (House)

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House) Legislation and Regulation - None Letters - None Action Alerts - None Miscellaneous - None

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve, and must be closed. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Community Bank Positions on New and Emerging Issues - Leadership for Bank Regulatory Agencies (Administration, Congress, and the Agencies) Recent nominees have held extreme views on the banking system and financial services and their nominations have increasingly caused unproductive political wrangling. Nominees should be qualified, hold reasonable positions, be willing to work collegially and cooperatively with colleagues and counterparts, serve the best interests of the banking and financial system and economy, and clearly understand the vital importance of and support community banks. Fintechs and Innovation in Financial Services (Congress and the Agencies) Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Special Purpose National Banks (SPNBs) (OCC) SPNBs, raise many concerns. They cannot have the advantages of a bank charter with limited requirements, regulations, and liability. Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. SBA Direct Lending (Congress) Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Financial Inclusion (Congress and the Agencies) CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking (Congress) Public banking (i.e., publicly-owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Current Expected Credit Loss Model (CECL) (FASB and the Agencies) Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements fall disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Nonsufficient Funds (Overdraft) Policies and Practices (OCC and the CFPB) CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include including returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Climate Risks (Administration, Congress, and the Agencies) CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporating material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. Bank Merger Activity (Congress and the Agencies) New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and FDIC) Legislation and Regulation - H.R. 5912 - Close the ILC Loophole Act (all sections) which is legislation to reform the regulation of industrial loan companies (ILCs) and their parent companies to provide for consolidated federal supervision (House) H.R. 4421 - America COMPETES Act of 2022 (in conference committee/reconciliation) H.R. 1996 - The SAFE Banking Act which permits the banking of cannabis related businesses in states where it is legal (House and Senate) H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) H.R. 7768 - Farm Credit Administration Independence Authority Act (all sections) which is legislation to exempt the Farm Credit System from being regulated by the CFPB and from compliance with Section 1071 of the Dodd-Frank Act - small business data collection (House) H.R. 2543 - Federal Reserve Racial and Economic Equity Act - Amendment to include H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) Letters - Comment Letter to the Federal Reserve System regarding: Supplemental Notice and request for Comments, Guidelines for Evaluating Account and Service Requests - Docket No. OP-1747 (Federal Reserve) Comment Letter to the FDIC regarding: Statement of Principles for Climate-Related Financial Risk Management for Large Financial Institutions - RIN 3064-ZA32 (FDIC) Comment Letter to the Federal Reserve regarding: Money and Payments: The Digital Dollar in the Age of Digital Transformation (Federal Reserve) Comment Letter to the FDIC regarding: Guidelines for Appeals of Material Supervisory Determinations - RIN 3064-ZA20 (FDIC) Action Alerts - Action Alert regarding: Expanded Credit Union Powers / H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) Miscellaneous - Comment Letter to the CFPB about Fees Imposed by Providers of Financial Products or Services (FDIC and House) Application to CFPBs regulatory sandbox (CFPB) Comment Letter to the Federal Reserve about Money and Payments: The Digital Dollar in the Age of Digital Transformation (House)

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Community Bank Positions on New and Emerging Issues - Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements fall disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Climate Risks (Administration, Congress, and the Agencies) CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporating material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House) Legislation and Regulation - H.R. 7768 - Farm Credit Administration Independence Authority Act (all sections) which is legislation to exempt the Farm Credit System from being regulated by the CFPB and from compliance with Section 1071 of the Dodd-Frank Act - small business data collection (House) Letters - None Action Alerts - None Miscellaneous - None

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve, and must be closed. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Community Bank Positions on New and Emerging Issues - Leadership for Bank Regulatory Agencies (Administration, Congress, and the Agencies) Recent nominees have held extreme views on the banking system and financial services and their nominations have increasingly caused unproductive political wrangling. Nominees should be qualified, hold reasonable positions, be willing to work collegially and cooperatively with colleagues and counterparts, serve the best interests of the banking and financial system and economy, and clearly understand the vital importance of and support community banks. Fintechs and Innovation in Financial Services (Congress and the Agencies) Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Special Purpose National Banks (SPNBs) (OCC) SPNBs, raise many concerns. They cannot have the advantages of a bank charter with limited requirements, regulations, and liability. Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. SBA Direct Lending (Congress) Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Financial Inclusion (Congress and the Agencies) CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking (Congress) Public banking (i.e., publicly-owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Current Expected Credit Loss Model (CECL) (FASB and the Agencies) Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements fall disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Nonsufficient Funds (Overdraft) Policies and Practices (OCC and the CFPB) CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include including returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Climate Risks (Administration, Congress, and the Agencies) CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporating material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. Bank Merger Activity (Congress and the Agencies) New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and OCC) Legislation and Regulation - H.R. 5912 - Close the ILC Loophole Act (all sections) which is legislation to reform the regulation of industrial loan companies (ILCs) and their parent companies to provide for consolidated federal supervision (House) Funding bill for the remainder of FY 2022 - Increase the authorization level for the SBAs 7(a) program because of higher-than-expected demand to prevent a shortfall (House and Senate) Letters - Comment Letter to the CFPB regarding: Small Business Lending Data Collection under the Equal Credit Opportunity Act (Regulation B) - Docket No. CFPB-2021-0015 and RIN 3170-AA09 (CFPB) Comment Letter to the CFPB regarding: Request for Information - Fees Imposed by Providers of Consumer Financial Products or Services; Docket No.: CFPB-2022-0003 (CFPB and OCC)

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Community Bank Positions on New and Emerging Issues - Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements fall disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Climate Risks (Administration, Congress, and the Agencies) CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporating material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and OCC) Letters - Comment Letter to the CFPB regarding: Re: Small Business Lending Data Collection under the Equal Credit Opportunity Act (Regulation B) - Docket No. CFPB-2021-0015 and RIN 3170-AA09 (CFPB)

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve, and must be closed. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Community Bank Positions on New and Emerging Issues - Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Financial Inclusion (Congress and the Agencies) CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Postal Banking (Congress) Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking (Congress) Public banking (i.e., publicly-owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Nonsufficient Funds (Overdraft) Policies and Practices (OCC and the CFPB) CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include including returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and OCC) Letters - Comment Letter to the CFPB regarding: Request for Information - Fees Imposed by Providers of Consumer Financial Products or Services; Docket No.: CFPB-2022-0003 (CFPB and OCC)

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Community Bank Positions on New and Emerging Issues - Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. SBA Direct Lending (Congress) Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements fall disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Climate Risks (Administration, Congress, and the Agencies) CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporating material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and OCC) Legislation and Regulation - Funding bill for the remainder of FY 2022 - Increase the authorization level for the SBAs 7(a) program because of higher-than-expected demand to prevent a shortfall (House and Senate) Letters - Comment Letter to the CFPB regarding: Small Business Lending Data Collection under the Equal Credit Opportunity Act (Regulation B) - Docket No. CFPB-2021-0015 and RIN 3170-AA09 (CFPB)

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and OCC)

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Community Bank Positions on New and Emerging Issues - Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and OCC)

CBAI 2021 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, and SARs) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce, because of the risks they pose to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole that excludes their holding companies from being supervised and regulated by the Federal Reserve must be closed. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must agree on joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act which provides this legal safe harbor. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. The Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Community Bank Positions on Emerging Issues Fintechs and Special Purpose Fintech National Bank (SPNBs) - OCC Fintechs, including the OCCs SPNBs, raise many concerns. They cannot have the advantages of a bank charter with limited requirements, regulations, and liability. Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Current Expected Credit Loss Model (CECL) - FASB Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. Customer Data Sharing - CFPB Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection - CFPB Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks, and Section 1071 should either be repealed, or community banks should be provided with a meaningful exception. Reporting Beneficial Ownership Information - FinCEN Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax - Congress Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate) Legislation and Regulation - Potential proposal in the Build Back Better Act (BBB) (commonly known as the IRS Reporting Plan) to force banks (and other financial service providers) to collect and report new and detailed information to the Internal Revenue Service (IRS) on consumer and business account activity (House and Senate) Proposal in legislation known as Build Back Better Act (BBB) to allocate funds to permit the U.S. Small Business Administration to directly originate and disburse SBA 7(a) loans (House and Senate) H.R. 5912 - Close the ILC Loophole Act (all sections) which is legislation to reform the regulation of industrial loan companies and their parent companies (House) H.R. 1977 - Enhancing Credit Opportunities in Rural America Act of 2021 (all sections) which is legislation to exempt from the calculation of interest received by a lender from real estate loans secured by agricultural real estate that is used in the production of agricultural products or from loans secured by a single-family principal residence in rural areas (House) H.R. 6037 (all sections) which is legislation to prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program (House and Senate) Letters - Comment Letter to the Farm Credit Administration regarding: Request for Input on Strategic Plan (Farm Credit Administration) Comment Letter to the Federal Reserve, OCC and the FDIC regarding: Proposed Interagency Guidance on Third-Party Relationships - Risk Management (Federal Reserve Docket No. OP-1752, FDIC RIN 3064-ZA26, and OCC Docket No. OCC-2021-0011) (Federal Reserve, OCC and FDIC) Action Alerts - Action Alert regarding proposal in legislation known as Build Back Better Acct (BBB) to allocate funds to permit the U.S. Small Business Administration to directly originate and disburse SBA 7(a) loans (House and Senate) Miscellaneous - Webinar on credit unions issues including reigning-in the expansionist agenda of the largest credit unions and tax-exempt credit unions buying taxpaying community banks (House) Professor Saule Omarova nomination to be Comptroller of the Currency (OCC) (Senate)

CBAI 2021 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, and SARs) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must agree on joint final rule to modernize the CRA. The Community Bank Positions on Emerging Issues Financial Transaction Tax - Congress Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate) Legislation and Regulation - Potential proposal in the Build Back Better Act (BBB) (commonly known as the IRS Reporting Plan) to force banks (and other financial service providers) to collect and report new and detailed information to the Internal Revenue Service (IRS) on consumer and business account activity (House and Senate) H.R. 1977 - Enhancing Credit Opportunities in Rural America Act of 2021 (all sections) which is legislation to exempt from the calculation of interest received by a lender from real estate loans secured by agricultural real estate that is used in the production of agricultural products or from loans secured by a single-family principal residence in rural areas (House) Letters - Comment Letter to the Farm Credit Administration regarding: Request for Input on Strategic Plan (Farm Credit Administration) Miscellaneous - Webinar on credit unions issues including reigning-in the expansionist agenda of the largest credit unions and tax-exempt credit unions buying taxpaying community banks (House)

CBAI 2021 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, and SARs) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce, because of the risks they pose to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole that excludes their holding companies from being supervised and regulated by the Federal Reserve must be closed. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must agree on joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act which provides this legal safe harbor. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. The Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Community Bank Positions on Emerging Issues Fintechs and Special Purpose Fintech National Bank (SPNBs) - OCC Fintechs, including the OCCs SPNBs, raise many concerns. They cannot have the advantages of a bank charter with limited requirements, regulations, and liability. Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Current Expected Credit Loss Model (CECL) - FASB Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. Customer Data Sharing - CFPB Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection - CFPB Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks, and Section 1071 should either be repealed, or community banks should be provided with a meaningful exception. Reporting Beneficial Ownership Information - FinCEN Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax - Congress Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate) Legislation and Regulation - Potential proposal in the Build Back Better Act (BBB) (commonly known as the IRS Reporting Plan) to force banks (and other financial service providers) to collect and report new and detailed information to the Internal Revenue Service (IRS) on consumer and business account activity (House and Senate) Proposal in legislation known as Build Back Better Act (BBB) to allocate funds to permit the U.S. Small Business Administration to directly originate and disburse SBA 7(a) loans (House and Senate) H.R. 5912 - Close the ILC Loophole Act (all sections) which is legislation to reform the regulation of industrial loan companies and their parent companies (House) H.R. 1977 - Enhancing Credit Opportunities in Rural America Act of 2021 (all sections) which is legislation to exempt from the calculation of interest received by a lender from real estate loans secured by agricultural real estate that is used in the production of agricultural products or from loans secured by a single-family principal residence in rural areas (House) H.R. 6037 (all sections) which is legislation to prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program (House and Senate) Letters - Comment Letter to the Farm Credit Administration regarding: Request for Input on Strategic Plan (Farm Credit Administration) Comment Letter to the Federal Reserve, OCC and the FDIC regarding: Proposed Interagency Guidance on Third-Party Relationships - Risk Management (Federal Reserve Docket No. OP-1752, FDIC RIN 3064-ZA26, and OCC Docket No. OCC-2021-0011) (Federal Reserve, OCC and FDIC) Action Alerts - Action Alert regarding proposal in legislation known as Build Back Better Acct (BBB) to allocate funds to permit the U.S. Small Business Administration to directly originate and disburse SBA 7(a) loans (House and Senate) Miscellaneous - Webinar on credit unions issues including reigning-in the expansionist agenda of the largest credit unions and tax-exempt credit unions buying taxpaying community banks (House) Professor Saule Omarova nomination to be Comptroller of the Currency (OCC) (Senate)

CBAI 2021 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, and SARs) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must agree on joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally-compliant cannabis-related business in states where cannabis is legal is a matter of public safety. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act which provides this legal safe harbor. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. The Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. The Community Bank Positions on Emerging Issues Customer Data Sharing - CFPB Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection - CFPB Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks, and Section 1071 should either be repealed, or community banks should be provided with a meaningful exception. Reporting Beneficial Ownership Information - FinCEN Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate) Legislation and Regulation - Potential proposal in the Build Back Better Act (BBB) (commonly known as the IRS Reporting Plan) to force banks (and other financial service providers) to collect and report new and detailed information to the Internal Revenue Service (IRS) on consumer and business account activity (House and Senate) H.R. 1977 - Enhancing Credit Opportunities in Rural America Act of 2021 (all sections) which is legislation to exempt from the calculation of interest received by a lender from real estate loans secured by agricultural real estate that is used in the production of agricultural products or from loans secured by a single-family principal residence in rural areas (House) Letters - Comment Letter to the Farm Credit Administration regarding: Request for Input on Strategic Plan (Farm Credit Administration)

CBAI 2021 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, and SARs) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must agree on joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act which provides this legal safe harbor. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. The Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Community Bank Positions on Emerging Issues Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Customer Data Sharing - CFPB Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate) Legislation and Regulations - Potential proposal in the Build Back Better Act (BBB) (commonly known as the IRS Reporting Plan) to force banks (and other financial service providers) to collect and report new and detailed information to the Internal Revenue Service (IRS) on consumer and business account activity (House and Senate) H.R. 1977 - Enhancing Credit Opportunities in Rural America Act of 2021 (all sections) which is legislation to exempt from the calculation of interest received by a lender from real estate loans secured by agricultural real estate that is used in the production of agricultural products or from loans secured by a single-family principal residence in rural areas (House) Miscellaneous - Webinar on credit unions issues including reigning-in the expansionist agenda of the largest credit unions and tax-exempt credit unions buying taxpaying community banks (House)

CBAI 2021 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, and SARs) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must agree on joint final rule to modernize the CRA. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate) Legislation and Regulation - H.R. 1977 - Enhancing Credit Opportunities in Rural America Act of 2021 (all sections) which is legislation to exempt from the calculation of interest received by a lender from real estate loans secured by agricultural real estate that is used in the production of agricultural products or from loans secured by a single-family principal residence in rural areas (House) Letters - Comment Letter to the Farm Credit Administration regarding: Request for Input on Strategic Plan (Farm Credit Administration) Miscellaneous - Webinar on credit unions issues including reigning-in the expansionist agenda of the largest credit unions and tax-exempt credit unions buying taxpaying community banks (House)

CBAI 2021 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, and SARs) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce, because of the risks they pose to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole that excludes their holding companies from being supervised and regulated by the Federal Reserve must be closed. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must agree on joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act which provides this legal safe harbor. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. The Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Community Bank Positions on Emerging Issues Fintechs and Special Purpose Fintech National Bank (SPNBs) - OCC Fintechs, including the OCCs SPNBs, raise many concerns. They cannot have the advantages of a bank charter with limited requirements, regulations, and liability. Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Current Expected Credit Loss Model (CECL) - FASB Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. Customer Data Sharing - CFPB Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection - CFPB Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks, and Section 1071 should either be repealed, or community banks should be provided with a meaningful exception. Reporting Beneficial Ownership Information - FinCEN Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax - Congress Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate) Legislation and Regulation - Amendment to the Budget Resolution offered by Senator Mike Crapo prohibiting monitoring and reporting of taxpayer information by banks to the IRS (Senate) Proposal in legislation known as Build Back Better to allocate funds to permit the U.S. Small Business Administration to directly originate and disburse SBA 7(a) loans over 10 years (House and Senate) Proposal in legislation known as the American Family Plan to increase various taxes including - corporate tax rate, individual tax rates, taxation of capital gains, deductions under the Tax Code Section 199A for shareholders of Subchapter S community banks and other pass through small businesses, a 3.8% net investment income tax on the income of Subchapter S shareholders, taxation at death or the removal of step-up basis, limitations on Section 1031 exchanges, and new requirements that banks transfer additional customer financial data to the IRS (House and Senate) Letters - Comment Letter to the Board of Governors of the Federal Reserve System regarding: Proposed Guidelines for Evaluating Account and Service Requests; Docket No. OP-1747 (Federal Reserve) Comment Letter to the Board of Governors of the Federal Reserve System regarding: Notice of Proposed Rulemaking - Debit Card Interchange Fees and Routing; Document No. R-1748 and RIN 7100-AG15 (Federal Reserve) Action Alerts - Action Alert regarding proposal for banks to collect and report customer accounts information (account flows) to the IRS (House and Senate) Action Alert regarding proposal in legislation known as the American Family Plan to increase various taxes including - corporate tax rate, individual tax rates, taxation of capital gains, deductions under the Tax Code Section 199A for shareholders of Subchapter S community banks and other pass through small businesses, a 3.8% net investment income tax on the income of Subchapter S shareholders, taxation at death or the removal of step-up basis, limitations on Section 1031 exchanges, and new requirements that banks transfer additional customer financial data to the IRS (House and Senate) Another Action Alert regarding proposal for banks to collect and report customer accounts information (account flows) to the IRS (House and Senate) Miscellaneous - Banking trade associations meeting with the Acting Comptroller of the OCC discussing topics including - the OCCs review of overdraft policies and practices, modernization of the CRA, novel (i.e., fintech) charters and banking powers, regulatory priorities-CECL versus faster payments, the proposed new plan for banks to collect and report customer accounts information (account flows) to the IRS (OCC) An extension of the Community Bank Leverage Ratio (CBLR) at 8.5% for an additional year through 2022 (House and Senate, Federal Reserve, FDIC, OCC)

CBAI 2021 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, and SARs) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must agree on joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act which provides this legal safe harbor. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Community Bank Positions on Emerging Issues Customer Data Sharing - CFPB Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection - CFPB Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks, and Section 1071 should either be repealed, or community banks should be provided with a meaningful exception. Reporting Beneficial Ownership Information - FinCEN Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate) Legislation and Regulation - Amendment to the Budget Resolution offered by Senator Mike Crapo prohibiting monitoring and reporting of taxpayer information by banks to the IRS (Senate) Proposal in legislation known as the American Family Plan to increase various taxes including - corporate tax rate, individual tax rates, taxation of capital gains, deductions under the Tax Code Section 199A for shareholders of Subchapter S community banks and other pass through small businesses, a 3.8% net investment income tax on the income of Subchapter S shareholders, taxation at death or the removal of step-up basis, limitations on Section 1031 exchanges, and new requirements that banks transfer additional customer financial data to the IRS (House and Senate) Proposal in legislation known as Build Back Better to allocate funds to permit the U.S. Small Business Administration to directly originate and disburse SBA 7(a) loans over 10 years (House and Senate) Letters - Comment Letter to the Board of Governors of the Federal Reserve System regarding: Notice of Proposed Rulemaking - Debit Card Interchange Fees and Routing; Document No. R-1748 and RIN 7100-AG15 (Federal Reserve) Action Alerts - Action Alert regarding proposal for banks to collect and report customer accounts information (account flows) to the IRS (House and Senate) Action Alert regarding proposal in legislation known as the American Family Plan to increase various taxes including - corporate tax rate, individual tax rates, taxation of capital gains, deductions under the Tax Code Section 199A for shareholders of Subchapter S community banks and other pass through small businesses, a 3.8% net investment income tax on the income of Subchapter S shareholders, taxation at death or the removal of step-up basis, limitations on Section 1031 exchanges, and new requirements that banks transfer additional customer financial data to the IRS (House and Senate) Another Action Alert regarding proposal for banks to collect and report customer accounts information (account flows) to the IRS (House and Senate) Miscellaneous - Banking trade associations meeting with the Acting Comptroller of the OCC discussing topics including - the OCCs review of overdraft policies and practices, modernization of the CRA, novel (i.e., fintech) charters and banking powers, regulatory priorities-CECL versus faster payments, the proposed new plan for banks to collect and report customer accounts information (account flows) to the IRS (OCC)

CBAI 2021 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, and SARs) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must agree on joint final rule to modernize the CRA. The Community Bank Positions on Emerging Issues Financial Transaction Tax - Congress Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate) Legislation and Regulation - Amendment to the Budget Resolution offered by Senator Mike Crapo prohibiting monitoring and reporting of taxpayer information by banks to the IRS (Senate) Proposal in legislation known as the American Family Plan to increase various taxes including - corporate tax rate, individual tax rates, taxation of capital gains, deductions under the Tax Code Section 199A for shareholders of Subchapter S community banks and other pass through small businesses, a 3.8% net investment income tax on the income of Subchapter S shareholders, taxation at death or the removal of step-up basis, limitations on Section 1031 exchanges, and new requirements that banks transfer additional customer financial data to the IRS (House and Senate) Letters - None Action Alerts - Action Alert regarding proposal for banks to collect and report customer accounts information (account flows) to the IRS (House and Senate) Action Alert regarding proposal in legislation known as the American Family Plan to increase various taxes including - corporate tax rate, individual tax rates, taxation of capital gains, deductions under the Tax Code Section 199A for shareholders of Subchapter S community banks and other pass through small businesses, a 3.8% net investment income tax on the income of Subchapter S shareholders, taxation at death or the removal of step-up basis, limitations on Section 1031 exchanges, and new requirements that banks transfer additional customer financial data to the IRS (House and Senate) Another Action Alert regarding proposal for banks to collect and report customer accounts information (account flows) to the IRS (House and Senate) Miscellaneous - Banking trade associations meeting with the Acting Comptroller of the OCC discussing topics including - the OCCs review of overdraft policies and practices, modernization of the CRA, novel (i.e., fintech) charters and banking powers, regulatory priorities-CECL versus faster payments, the proposed new plan for banks to collect and report customer accounts information (account flows) to the IRS (OCC)

CBAI 2021 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, and SARs) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce, because of the risks they pose to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole that excludes their holding companies from being supervised and regulated by the Federal Reserve must be closed. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must agree on joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act which provides this legal safe harbor. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. The Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Community Bank Positions on Emerging Issues Fintechs and Special Purpose Fintech National Bank (SPNBs) - OCC Fintechs, including the OCCs SPNBs, raise many concerns. They cannot have the advantages of a bank charter with limited requirements, regulations, and liability. Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Current Expected Credit Loss Model (CECL) - FASB Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. Customer Data Sharing - CFPB Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection - CFPB Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks, and Section 1071 should either be repealed, or community banks should be provided with a meaningful exception. Reporting Beneficial Ownership Information - FinCEN Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax - Congress Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate) Legislation and Regulation - Amendment to the Budget Resolution offered by Senator Mike Crapo prohibiting monitoring and reporting of taxpayer information by banks to the IRS (Senate) Proposal in legislation known as Build Back Better to allocate funds to permit the U.S. Small Business Administration to directly originate and disburse SBA 7(a) loans over 10 years (House and Senate) Proposal in legislation known as the American Family Plan to increase various taxes including - corporate tax rate, individual tax rates, taxation of capital gains, deductions under the Tax Code Section 199A for shareholders of Subchapter S community banks and other pass through small businesses, a 3.8% net investment income tax on the income of Subchapter S shareholders, taxation at death or the removal of step-up basis, limitations on Section 1031 exchanges, and new requirements that banks transfer additional customer financial data to the IRS (House and Senate) Letters - Comment Letter to the Board of Governors of the Federal Reserve System regarding: Proposed Guidelines for Evaluating Account and Service Requests; Docket No. OP-1747 (Federal Reserve) Comment Letter to the Board of Governors of the Federal Reserve System regarding: Notice of Proposed Rulemaking - Debit Card Interchange Fees and Routing; Document No. R-1748 and RIN 7100-AG15 (Federal Reserve) Action Alerts - Action Alert regarding proposal for banks to collect and report customer accounts information (account flows) to the IRS (House and Senate) Action Alert regarding proposal in legislation known as the American Family Plan to increase various taxes including - corporate tax rate, individual tax rates, taxation of capital gains, deductions under the Tax Code Section 199A for shareholders of Subchapter S community banks and other pass through small businesses, a 3.8% net investment income tax on the income of Subchapter S shareholders, taxation at death or the removal of step-up basis, limitations on Section 1031 exchanges, and new requirements that banks transfer additional customer financial data to the IRS (House and Senate) Another Action Alert regarding proposal for banks to collect and report customer accounts information (account flows) to the IRS (House and Senate) Miscellaneous - Banking trade associations meeting with the Acting Comptroller of the OCC discussing topics including - the OCCs review of overdraft policies and practices, modernization of the CRA, novel (i.e., fintech) charters and banking powers, regulatory priorities-CECL versus faster payments, the proposed new plan for banks to collect and report customer accounts information (account flows) to the IRS (OCC) An extension of the Community Bank Leverage Ratio (CBLR) at 8.5% for an additional year through 2022 (House and Senate, Federal Reserve, FDIC, OCC)

CBAI 2021 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, and SARs) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must agree on joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally-compliant cannabis-related business in states where cannabis is legal is a matter of public safety. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act which provides this legal safe harbor. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. The Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. The Community Bank Positions on Emerging Issues Customer Data Sharing - CFPB Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection - CFPB Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks, and Section 1071 should either be repealed, or community banks should be provided with a meaningful exception. Reporting Beneficial Ownership Information - FinCEN Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate) Legislation and Regulation - Amendment to the Budget Resolution offered by Senator Mike Crapo prohibiting monitoring and reporting of taxpayer information by banks to the IRS (Senate) Proposal in legislation known as the American Family Plan to increase various taxes including - corporate tax rate, individual tax rates, taxation of capital gains, deductions under the Tax Code Section 199A for shareholders of Subchapter S community banks and other pass through small businesses, a 3.8% net investment income tax on the income of Subchapter S shareholders, taxation at death or the removal of step-up basis, limitations on Section 1031 exchanges, and new requirements that banks transfer additional customer financial data to the IRS (House and Senate) Letters - None Action Alerts - Action Alert regarding proposal for banks to collect and report customer accounts information (account flows) to the IRS (House and Senate) Action Alert regarding proposal in legislation known as the American Family Plan to increase various taxes including - corporate tax rate, individual tax rates, taxation of capital gains, deductions under the Tax Code Section 199A for shareholders of Subchapter S community banks and other pass through small businesses, a 3.8% net investment income tax on the income of Subchapter S shareholders, taxation at death or the removal of step-up basis, limitations on Section 1031 exchanges, and new requirements that banks transfer additional customer financial data to the IRS (House and Senate) Another Action Alert regarding proposal for banks to collect and report customer accounts information (account flows) to the IRS (House and Senate) Miscellaneous - Banking trade associations meeting with the Acting Comptroller of the OCC discussing topics including - the OCCs review of overdraft policies and practices, modernization of the CRA, novel (i.e., fintech) charters and banking powers, regulatory priorities-CECL versus faster payments, the proposed new plan for banks to collect and report customer accounts information (account flows) to the IRS (OCC)

CBAI 2021 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, and SARs) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must agree on joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act which provides this legal safe harbor. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. The Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Community Bank Positions on Emerging Issues Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Customer Data Sharing - CFPB Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate) Legislation and Regulations - Amendment to the Budget Resolution offered by Senator Mike Crapo prohibiting monitoring and reporting of taxpayer information by banks to the IRS (Senate) Proposal in legislation known as the American Family Plan to increase various taxes including - corporate tax rate, individual tax rates, taxation of capital gains, deductions under the Tax Code Section 199A for shareholders of Subchapter S community banks and other pass through small businesses, a 3.8% net investment income tax on the income of Subchapter S shareholders, taxation at death or the removal of step-up basis, limitations on Section 1031 exchanges, and new requirements that banks transfer additional customer financial data to the IRS (House and Senate) Letters - Comment Letter to the Board of Governors of the Federal Reserve System regarding: Notice of Proposed Rulemaking - Debit Card Interchange Fees and Routing; Document No. R-1748 and RIN 7100-AG15 (Federal Reserve) Action Alerts - Action Alert regarding proposal for banks to collect and report customer accounts information (account flows) to the IRS (House and Senate) Action Alert regarding proposal in legislation known as the American Family Plan to increase various taxes including - corporate tax rate, individual tax rates, taxation of capital gains, deductions under the Tax Code Section 199A for shareholders of Subchapter S community banks and other pass through small businesses, a 3.8% net investment income tax on the income of Subchapter S shareholders, taxation at death or the removal of step-up basis, limitations on Section 1031 exchanges, and new requirements that banks transfer additional customer financial data to the IRS (House and Senate) Another Action Alert regarding proposal for banks to collect and report customer accounts information (account flows) to the IRS (House and Senate) Miscellaneous - Banking trade associations meeting with the Acting Comptroller of the OCC discussing topics including - the OCCs review of overdraft policies and practices, modernization of the CRA, novel (i.e., fintech) charters and banking powers, regulatory priorities-CECL versus faster payments, the proposed new plan for banks to collect and report customer accounts information (account flows) to the IRS (OCC)

CBAI 2021 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, and SARs) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must agree on joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally-compliant cannabis-related business in states where cannabis is legal is a matter of public safety. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act which provides this legal safe harbor. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. The Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. The Community Bank Positions on Emerging Issues Customer Data Sharing - CFPB Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection - CFPB Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks, and Section 1071 should either be repealed, or community banks should be provided with a meaningful exception. Reporting Beneficial Ownership Information - FinCEN Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate) Legislation and Regulation - H.R. 2186 - Beginning Agriculturalist Lifetime Employment Act of 2021 (BALE Act) (All Sections) Regarding increasing the percentage of USDA loan guarantee for beginning farmers or ranchers or socially disadvantaged farmers or ranchers (House) H.R. 1977 - Enhancing Credit Opportunities in Rural America Act (ECORA) (All Sections) Regarding exempting from taxes interest earned on loans from farm real estate and rural mortgage loans (House) Letters - Comment Letter to the Financial Crimes Enforcement Network regarding: Beneficial Ownership Reporting Requirements - Document Number FINCEN-2021-0005 and RIN 1506-AB49 (FinCEN) Action Alerts - Action Alert regarding Presidents proposal for the IRS to collect and report account flows on bank customers (House and Senate) Miscellaneous - Modernization of the CRA (House) Minding the Tax Gap Ways and Means Committee hearing regarding proposal for the IRS to collect and report account flows on bank customers (House)

CBAI 2021 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, and SARs) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must agree on joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act which provides this legal safe harbor. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. The Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Community Bank Positions on Emerging Issues Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Customer Data Sharing - CFPB Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate) Legislation and Regulations - H.R. 1977 - Enhancing Credit Opportunities in Rural America Act (ECORA) (All Sections) Regarding exempting from taxes interest earned on loans from farm real estate and rural mortgage loans (House) H.R. 3076 - Postal Service Reform Act (Section 103 - Non-Postal Services) as it relates to the possibility of Postal Banking (House) Letters - Letters to the Federal Housing Finance Authority regarding Preferred Stock Purchase Amendments restrictive caps for loans to second homes and investment properties, and cash window volume limits (FHFA) Action Alerts - Action Alert regarding Presidents proposal for the IRS to collect and report account flows on bank customers (House and Senate) Miscellaneous - Modernization of the CRA (House) US Postal Service and public banking (House) Minding the Tax Gap Ways and Means Committee hearing regarding proposal for the IRS to collect and report account flows on bank customers (House) OCC True Lender rule and the Congressional Review Act (House)

CBAI 2021 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, and SARs) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must agree on joint final rule to modernize the CRA. The Community Bank Positions on Emerging Issues Financial Transaction Tax - Congress Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate) Legislation and Regulation - H.R. 1977 - Enhancing Credit Opportunities in Rural America Act (ECORA) (All Sections) Regarding exempting from taxes interest earned on loans from farm real estate and rural mortgage loans (House) Letters - None Action Alerts - Action Alert regarding Congressional hearings on credit union expansion, particularly the purchase of taxpaying community banks by tax-exempt credit unions (House and Senate) Miscellaneous - Modernization of the CRA (House) The Financial Transaction Tax (House) Minding the Tax Gap Ways and Means Committee hearing regarding proposal for the IRS to collect and report account flows on bank customers (House)

CBAI 2021 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, and SARs) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce, because of the risks they pose to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole that excludes their holding companies from being supervised and regulated by the Federal Reserve must be closed. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must agree on joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act which provides this legal safe harbor. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. The Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Community Bank Positions on Emerging Issues Fintechs and Special Purpose Fintech National Bank (SPNBs) - OCC Fintechs, including the OCCs SPNBs, raise many concerns. They cannot have the advantages of a bank charter with limited requirements, regulations, and liability. Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Current Expected Credit Loss Model (CECL) - FASB Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. Customer Data Sharing - CFPB Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection - CFPB Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks, and Section 1071 should either be repealed, or community banks should be provided with a meaningful exception. Reporting Beneficial Ownership Information - FinCEN Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax - Congress Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate) Legislation and Regulation - H.R. 1996 - SAFE Act (All Sections) Regarding safe harbor for banks that choose to provide financial services to cannabis related businesses (House) H.R. 2186 - Beginning Agriculturalist Lifetime Employment Act of 2021 (BALE Act) (All Sections) Regarding increasing the percentage of USDA loan guarantee for beginning farmers or ranchers or socially disadvantaged farmers or ranchers (House) H.R. 1977 - Enhancing Credit Opportunities in Rural America Act (ECORA) (All Sections) Regarding exempting from taxes interest earned on loans from farm real estate and rural mortgage loans (House) H.R. 3076 - Postal Service Reform Act (Section 103 - Non-Postal Services) as it relates to the possibility of Postal Banking (House) Letters - Letters to the Federal Housing Finance Authority regarding Preferred Stock Purchase Amendments restrictive caps for loans to second homes and investment properties, and cash window volume limits (FHFA) Letter to the Financial Crimes Enforcement Network regarding Administrative Ruling to exempt financial institutions from filing CTRs on certain armored car services and money service businesses (FinCEN) Comment Letter to the Financial Crimes Enforcement Network regarding: Beneficial Ownership Reporting Requirements - Document Number FINCEN-2021-0005 and RIN 1506-AB49 (FinCEN) Action Alerts - Action Alert regarding Congressional hearings on credit union expansion, particularly the purchase of taxpaying community banks by tax-exempt credit unions (House and Senate) Action Alert regarding Presidents proposal for the IRS to collect and report account flows on bank customers (House and Senate) Miscellaneous - US Postal Service and public banking (House) Modernization of the CRA (House) The Financial Transaction Tax (House) Closing the Industrial Loan Company (ILC) regulatory loophole for consolidated supervision by the Federal Reserve of ILC parent holding companies (House and Senate) Minding the Tax Gap Ways and Means Committee hearing regarding proposal for the IRS to collect and report account flows on bank customers (House) OCC True Lender rule and the Congressional Review Act (House)

CBAI 2021 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, and SARs) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must agree on joint final rule to modernize the CRA. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate) Legislation and Regulation - None Letters - None Action Alerts - None Miscellaneous - Modernization of the CRA (House)

CBAI 2021 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, and SARs) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce, because of the risks they pose to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole that excludes their holding companies from being supervised and regulated by the Federal Reserve must be closed. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must agree on joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act which provides this legal safe harbor. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. The Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Community Bank Positions on Emerging Issues Fintechs and Special Purpose Fintech National Bank (SPNBs) - OCC Fintechs, including the OCCs SPNBs, raise many concerns. They cannot have the advantages of a bank charter with limited requirements, regulations, and liability. Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Current Expected Credit Loss Model (CECL) - FASB Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. Customer Data Sharing - CFPB Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection - CFPB Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks, and Section 1071 should either be repealed, or community banks should be provided with a meaningful exception. Reporting Beneficial Ownership Information - FinCEN Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax - Congress Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate) Legislation and Regulation - H.R. 1996 - SAFE Act (All Sections) Regarding safe harbor for banks that choose to provide financial services to cannabis related businesses (House) H.R. 2186 - Beginning Agriculturalist Lifetime Employment Act of 2021 (BALE Act) (All Sections) Regarding increasing the percentage of USDA loan guarantee for beginning farmers or ranchers or socially disadvantaged farmers or ranchers (House) H.R. 1977 - Enhancing Credit Opportunities in Rural America Act (ECORA) (All Sections) Regarding exempting from taxes interest earned on loans from farm real estate and rural mortgage loans (House) H.R. 3076 - Postal Service Reform Act (Section 103 - Non-Postal Services) as it relates to the possibility of Postal Banking (House) Letters - Letters to the Federal Housing Finance Authority regarding Preferred Stock Purchase Amendments restrictive caps for loans to second homes and investment properties, and cash window volume limits (FHFA) Letter to the Financial Crimes Enforcement Network regarding Administrative Ruling to exempt financial institutions from filing CTRs on certain armored car services and money service businesses (FinCEN) Comment Letter to the Financial Crimes Enforcement Network regarding: Beneficial Ownership Reporting Requirements - Document Number FINCEN-2021-0005 and RIN 1506-AB49 (FinCEN) Action Alerts - Action Alert regarding Congressional hearings on credit union expansion, particularly the purchase of taxpaying community banks by tax-exempt credit unions (House and Senate) Action Alert regarding Presidents proposal for the IRS to collect and report account flows on bank customers (House and Senate) Miscellaneous - US Postal Service and public banking (House) Modernization of the CRA (House) The Financial Transaction Tax (House) Closing the Industrial Loan Company (ILC) regulatory loophole for consolidated supervision by the Federal Reserve of ILC parent holding companies (House and Senate) Minding the Tax Gap Ways and Means Committee hearing regarding proposal for the IRS to collect and report account flows on bank customers (House) OCC True Lender rule and the Congressional Review Act (House)

CBAI 2020 Federal Policy Priorities - Community Bank Response to the COVID-19 Crisis COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) The banking regulators have almost completed implementing S. 2155 so community banks can benefit from all of the regulatory relief measures. Community bankers, the associations that represent their interests, and Congress (which represent this vital economic constituency) must diligently insist on the swift completion the rulemaking - consistent with Congressional intent. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs , SARs, tax exempt interest on agricultural and small business loans, and beneficial ownership reporting) to permit them to serve their customers and communities better and more efficiently. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purposes, blatantly abusing their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, it is a matter of public safety to have a safe harbor from federal sanctions for financial institutions that choose to serve legally-compliant cannabis-related business in states where cannabis is legal. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act of 2019 (H.R. 1595) which provides this legal safe harbor. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. The Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Community Bank Positions on Emerging Issues CFPB - Customer Data Sharing Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. CFPB - Small-Dollar Consumer Lending Appropriate action will be required, as the revised implementation of the rule unfolds to assure appropriate and responsible access to small dollar loans by consumers and to minimize any negative impact on community banks small-dollar consumer lending. Federal Reserve - Modernize Reg CC Fraud losses are increasing at community banks and Reg CC needs to keep pace with the technology. All banks, credit unions, and others who utilize the payments system should be operating on the same level playing field when it comes to return reasons for fraud and acknowledging and communicating about fraud. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, CFPB, OCC, FDIC, Federal Reserve) Letters - Comment Letter to the Consumer Financial Protection Bureau (CFPB) regarding: Consumer Access to Financial Records - Docket No CFPB-2020-0034 and RIN 3170-AA78 (CFPB) Comment Letter to the Federal Reserve regarding: Community Reinvestment Act - Advance Notice of Proposed Rulemaking - Docket No. R-1723 and RIN 7100-AF94 (Federal Reserve House, Senate, OCC, FDIC) Miscellaneous - US Postal Service banking (Senate and House) Credit Unions - challenging their tax exemption and unfair competition with community banks (House and Senate) Small-dollar consumer lending - opportunities and challenges (House)

CBAI 2020 Federal Policy Priorities - Community Bank Response to the COVID-19 Crisis COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) The banking regulators have almost completed implementing S. 2155 so community banks can benefit from all of the regulatory relief measures. Community bankers, the associations that represent their interests, and Congress (which represent this vital economic constituency) must diligently insist on the swift completion the rulemaking - consistent with Congressional intent. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs , SARs, tax exempt interest on agricultural and small business loans, and beneficial ownership reporting) to permit them to serve their customers and communities better and more efficiently. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purposes, blatantly abusing their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in and the playing field leveled for community banks. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, it is a matter of public safety to have a safe harbor from federal sanctions for financial institutions that choose to serve legally-compliant cannabis-related business in states where cannabis is legal. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act of 2019 (H.R. 1595) which provides this legal safe harbor. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Community Bank Positions on Emerging Issues CFPB - Small Business Data Collection Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks, and Section 1071 should either be repealed, or community banks should be provided with a meaningful exception. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, CFPB, OCC, FDIC, Federal Reserve) Legislation and Regulation - Beginning Agriculturalist Lifetime Employment Act of 2021 (BALE Act (no bill number yet) (All Sections) Regarding increasing the percentage of USDA loan guarantee for beginning farmers or ranchers or socially disadvantaged farmers or ranchers (House) H.R. 1799 - PPP Extension Act of 2021 (All Sections) Regarding extending the Paycheck Protection Program through June 30, 2021 (House and Senate) H.R. 1977 - Enhancing Credit Opportunities in Rural America Act (ECORA) (All Sections) Regarding exempting from taxes interest earned on loans from farm real estate and rural mortgage loans (House and Senate) H.R. 1996 - SAFE Act (All Sections) Regarding safe harbor for banks that choose to provide financial services to cannabis related businesses (House) Letters - Comment Letter to the Federal Reserve regarding: Community Reinvestment Act - Advance Notice of Proposed Rulemaking - Docket No. R-1723 and RIN 7100-AF94 (Federal Reserve House, Senate, OCC, FDIC) Action Alerts - Action Alert regarding fixes to the Paycheck Protection Program (PPP) including - small businesses not being able to borrow up to the maximum first round draw amount, in spite of a legislative rule change for the second round, because the small business had been granted first round PPP forgiveness; small businesses with modest shortfalls in using first draw dollars should be eligible for second draw loans; and self-employed farmers and ranchers should be permitted to use the gross income method so they have access to the PPP (House and Senate) Action Alert regarding cosponsoring H.R. 1977 - Enhancing Credit Opportunities in Rural America Act (ECORA) which exempts from taxes interest earned on loans from farm real estate and rural mortgage loans (House and Senate) Miscellaneous - Potential reintroduction of legislation to exempt community banks from taxation on income from small dollar amount small business and agriculture loans to begin to provide parity with Farm Credit lenders and credit unions (Senate) Paycheck Protection Program (PPP) CBAI member polling results (House, Senate, CFPB, OCC, FDIC, Federal Reserve) Paycheck Protection Program (PPP) issue with small businesses not being able to borrow up to the maximum first round draw amount, in spite of a legislative rule change for the second round, because the small business had been granted first round PPP forgiveness (House, Senate, CFPB, OCC, FDIC, Federal Reserve) Farm Credit System lending (preferential treatment and unfair competition with community banks, fraud in the Paycheck Protection Program (PPP) lending - SBA IG Report (Number 20-21) and Bloomberg Businessweek headline PPP Scammers Made Fintech Companies Their Lenders of Choice (Senate) Paycheck Protection Program (PPP) - ramping the reduction in gross receipts (versus all or nothing) to enable more small business borrowers to qualify for the second round of PPP funding (House)

CBAI 2020 Federal Policy Priorities - Community Bank Response to the COVID-19 Crisis COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) The banking regulators have almost completed implementing S. 2155 so community banks can benefit from all of the regulatory relief measures. Community bankers, the associations that represent their interests, and Congress (which represent this vital economic constituency) must diligently insist on the swift completion the rulemaking - consistent with Congressional intent. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs , SARs, tax exempt interest on agricultural and small business loans, and beneficial ownership reporting) to permit them to serve their customers and communities better and more efficiently. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purposes, blatantly abusing their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in and the playing field leveled for community banks. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, it is a matter of public safety to have a safe harbor from federal sanctions for financial institutions that choose to serve legally-compliant cannabis-related business in states where cannabis is legal. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act of 2019 (H.R. 1595) which provides this legal safe harbor. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. The Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. The Community Bank Positions on Emerging Issues CFPB - Small Business Data Collection Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks, and Section 1071 should either be repealed, or community banks should be provided with a meaningful exception. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, CFPB, OCC, FDIC, Federal Reserve) Legislation and Regulation - Beginning Agriculturalist Lifetime Employment Act of 2021 (BALE Act (no bill number yet) (All Sections) Regarding increasing the percentage of USDA loan guarantee for beginning farmers or ranchers or socially disadvantaged farmers or ranchers (House) H.R. 1799 - PPP Extension Act of 2021 (All Sections) Regarding extending the Paycheck Protection Program through June 30, 2021 (House and Senate) H.R. 1977 - Enhancing Credit Opportunities in Rural America Act (ECORA) (All Sections) Regarding exempting from taxes interest earned on loans from farm real estate and rural mortgage loans (House and Senate) H.R. 1996 - SAFE Act (All Sections) Regarding safe harbor for banks that choose to provide financial services to cannabis related businesses (House) Letters - Comment Letter to the Federal Reserve regarding: Community Reinvestment Act - Advance Notice of Proposed Rulemaking - Docket No. R-1723 and RIN 7100-AF94 (Federal Reserve House, Senate, OCC, FDIC) Action Alerts - Action Alert regarding fixes to the Paycheck Protection Program (PPP) including - small businesses not being able to borrow up to the maximum first round draw amount, in spite of a legislative rule change for the second round, because the small business had been granted first round PPP forgiveness; small businesses with modest shortfalls in using first draw dollars should be eligible for second draw loans; and self-employed farmers and ranchers should be permitted to use the gross income method so they have access to the PPP (House and Senate) Action Alert regarding cosponsoring H.R. 1977 - Enhancing Credit Opportunities in Rural America Act (ECORA) which exempts from taxes interest earned on loans from farm real estate and rural mortgage loans (House and Senate) Miscellaneous - Potential reintroduction of legislation to exempt community banks from taxation on income from small dollar amount small business and agriculture loans to begin to provide parity with Farm Credit lenders and credit unions (Senate) Paycheck Protection Program (PPP) CBAI member polling results (House, Senate, CFPB, OCC, FDIC, Federal Reserve) Paycheck Protection Program (PPP) issue with small businesses not being able to borrow up to the maximum first round draw amount, in spite of a legislative rule change for the second round, because the small business had been granted first round PPP forgiveness (House, Senate, CFPB, OCC, FDIC, Federal Reserve) US Postal Service banking, Farm Credit System lending (preferential treatment and unfair competition with community banks, and fraud in the Paycheck Protection Program (PPP) lending - SBA IG Report (Number 20-21) and Bloomberg Businessweek headline PPP Scammers Made Fintech Companies Their Lenders of Choice (Senate) Paycheck Protection Program (PPP) - ramping the reduction in gross receipts (versus all or nothing) to enable more small business borrowers to qualify for the second round of PPP funding (House)

CBAI 2020 Federal Policy Priorities - Community Bank Response to the COVID-19 Crisis COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) The banking regulators have almost completed implementing S. 2155 so community banks can benefit from all of the regulatory relief measures. Community bankers, the associations that represent their interests, and Congress (which represent this vital economic constituency) must diligently insist on the swift completion the rulemaking - consistent with Congressional intent. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs , SARs, tax exempt interest on agricultural and small business loans, and beneficial ownership reporting) to permit them to serve their customers and communities better and more efficiently. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purposes, blatantly abusing their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in and the playing field leveled for community banks. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, CFPB, OCC, FDIC, Federal Reserve) Legislation and Regulation - H.R. 1977 - Enhancing Credit Opportunities in Rural America Act (ECORA) (All Sections) Regarding exempting from taxes interest earned on loans from farm real estate and rural mortgage loans (House and Senate) Letters - Comment Letter to the Federal Reserve regarding: Community Reinvestment Act - Advance Notice of Proposed Rulemaking - Docket No. R-1723 and RIN 7100-AF94 (Federal Reserve House, Senate, OCC, FDIC) Action Alerts - Action Alert regarding cosponsoring H.R. 1977 - Enhancing Credit Opportunities in Rural America Act (ECORA) which exempts from taxes interest earned on loans from farm real estate and rural mortgage loans (House and Senate) Miscellaneous - Potential reintroduction of legislation to exempt community banks from taxation on income from small dollar amount small business and agriculture loans to begin to provide parity with Farm Credit lenders and credit unions (Senate) Farm Credit System lending (preferential treatment and unfair competition with community banks (Senate) Credit Unions - challenging their tax exemption and unfair competition with community banks (House and Senate) Small-dollar consumer lending - opportunities and challenges (House)

CBAI 2020 Federal Policy Priorities - Community Bank Response to the COVID-19 Crisis COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) The banking regulators have almost completed implementing S. 2155 so community banks can benefit from all of the regulatory relief measures. Community bankers, the associations that represent their interests, and Congress (which represent this vital economic constituency) must diligently insist on the swift completion the rulemaking - consistent with Congressional intent. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs , SARs, tax exempt interest on agricultural and small business loans, and beneficial ownership reporting) to permit them to serve their customers and communities better and more efficiently. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purposes, blatantly abusing their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce, because of the risks they pose to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole that excludes their holding companies from being supervised and regulated by the Federal Reserve must be closed. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in and the playing field leveled for community banks. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Modifying the FDICs Brokered Deposit Rule The FDIC proposed brokered deposit rule needs to be updated to reflect modern ways of gathering deposits and they should not be viewed unfavorably, and subject to unreasonable restrictions. A properly tailored brokered deposit rule will ensure that it does not place undue limits on the reasonable use of brokered deposits by community banks. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, it is a matter of public safety to have a safe harbor from federal sanctions for financial institutions that choose to serve legally-compliant cannabis-related business in states where cannabis is legal. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act of 2019 (H.R. 1595) which provides this legal safe harbor. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Recent and encouraging signs by the FDIC to approve de novo charter applications must continue and many new banks should be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. The Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Community Bank Positions on Emerging Issues OCC - Special Purpose Fintech National Bank (SPNBs) Fintech Charters The Office of Comptroller of the Currency (OCC) intends to issue special purpose national banking charters to Fintech companies. Fintechs cannot have the advantages of a national bank charter with limited requirements, regulations, and liability. FASB - Current Expected Credit Loss Model (CECL) Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. CFPB - Customer Data Sharing Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. CFPB - Small-Dollar Consumer Lending Appropriate action will be required, as the revised implementation of the rule unfolds to assure appropriate and responsible access to small dollar loans by consumers and to minimize any negative impact on community banks small-dollar consumer lending. CFPB - Small Business Data Collection Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks, and Section 1071 should either be repealed, or community banks should be provided with a meaningful exception. Federal Reserve - Modernize Reg CC Fraud losses are increasing at community banks and Reg CC needs to keep pace with the technology. All banks, credit unions, and others who utilize the payments system should be operating on the same level playing field when it comes to return reasons for fraud and acknowledging and communicating about fraud. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, CFPB, OCC, FDIC, Federal Reserve) Legislation and Regulation - Beginning Agriculturalist Lifetime Employment Act of 2021 (BALE Act (no bill number yet) (All Sections) Regarding increasing the percentage of USDA loan guarantee for beginning farmers or ranchers or socially disadvantaged farmers or ranchers (House) H.R. 1799 - PPP Extension Act of 2021 (All Sections) Regarding extending the Paycheck Protection Program through June 30, 2021 (House and Senate) H.R. 1977 - Enhancing Credit Opportunities in Rural America Act (ECORA) (All Sections) Regarding exempting from taxes interest earned on loans from farm real estate and rural mortgage loans (House and Senate) H.R. 1996 - SAFE Act (All Sections) Regarding safe harbor for banks that choose to provide financial services to cannabis related businesses (House) Letters - Comment Letter to the Consumer Financial Protection Bureau (CFPB) regarding: Consumer Access to Financial Records - Docket No CFPB-2020-0034 and RIN 3170-AA78 (CFPB) Comment Letter to the Federal Reserve regarding: Community Reinvestment Act - Advance Notice of Proposed Rulemaking - Docket No. R-1723 and RIN 7100-AF94 (Federal Reserve House, Senate, OCC, FDIC) Action Alerts - Action Alert regarding fixes to the Paycheck Protection Program (PPP) including - small businesses not being able to borrow up to the maximum first round draw amount, in spite of a legislative rule change for the second round, because the small business had been granted first round PPP forgiveness; small businesses with modest shortfalls in using first draw dollars should be eligible for second draw loans; and self-employed farmers and ranchers should be permitted to use the gross income method so they have access to the PPP (House and Senate) Action Alert regarding cosponsoring H.R. 1977 - Enhancing Credit Opportunities in Rural America Act (ECORA) which exempts from taxes interest earned on loans from farm real estate and rural mortgage loans (House and Senate) Miscellaneous - Potential reintroduction of legislation to exempt community banks from taxation on income from small dollar amount small business and agriculture loans to begin to provide parity with Farm Credit lenders and credit unions (Senate) The OCCs approval of the conversion of Anchorage Trust Company to become Anchorage Digital Bank (OCC) Paycheck Protection Program (PPP) CBAI member polling results (House, Senate, CFPB, OCC, FDIC, Federal Reserve) Paycheck Protection Program (PPP) issue with small businesses not being able to borrow up to the maximum first round draw amount, in spite of a legislative rule change for the second round, because the small business had been granted first round PPP forgiveness (House, Senate, CFPB, OCC, FDIC, Federal Reserve) US Postal Service banking, Farm Credit System lending preferential treatment and unfair competition with community banks, and fraud in the Paycheck Protection Program (PPP) lending - SBA IG Report (Number 20-21) and Bloomberg Businessweek headline PPP Scammers Made Fintech Companies Their Lenders of Choice (Senate) US Postal Service banking (House) Paycheck Protection Program (PPP) - ramping the reduction in gross receipts (versus all or nothing) to enable more small business borrowers to qualify for the second round of PPP funding (House) Closing the Industrial Loan Company (ILC) regulatory loophole for consolidated supervision by the Federal Reserve of ILC parent holding companies ((Federal Reserve House, Senate, OCC, FDIC) Credit Unions - challenging their tax exemption and unfair competition with community banks (House and Senate) Small-dollar consumer lending - opportunities and challenges (House)

CBAI 2020 Federal Policy Priorities - Community Bank Response to the COVID-19 Crisis COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) The banking regulators have almost completed implementing S. 2155 so community banks can benefit from all of the regulatory relief measures. Community bankers, the associations that represent their interests, and Congress (which represent this vital economic constituency) must diligently insist on the swift completion the rulemaking - consistent with Congressional intent. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs , SARs, tax exempt interest on agricultural and small business loans, and beneficial ownership reporting) to permit them to serve their customers and communities better and more efficiently. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purposes, blatantly abusing their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in and the playing field leveled for community banks. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, CFPB, OCC, FDIC, Federal Reserve) Letters - Comment Letter to the Federal Reserve regarding: Community Reinvestment Act - Advance Notice of Proposed Rulemaking - Docket No. R-1723 and RIN 7100-AF94 (Federal Reserve House, Senate, OCC, FDIC)

CBAI 2020 Federal Policy Priorities - Community Bank Response to the COVID-19 Crisis COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) The banking regulators have almost completed implementing S. 2155 so community banks can benefit from all of the regulatory relief measures. Community bankers, the associations that represent their interests, and Congress (which represent this vital economic constituency) must diligently insist on the swift completion the rulemaking - consistent with Congressional intent. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs , SARs, tax exempt interest on agricultural and small business loans, and beneficial ownership reporting) to permit them to serve their customers and communities better and more efficiently. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purposes, blatantly abusing their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in and the playing field leveled for community banks. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, CFPB, OCC, FDIC, Federal Reserve) Letters - Comment Letter to the Federal Deposit Insurance Corporation (FDIC) regarding: Proposed Revisions to Statement of Policy Regarding Minority Depository Institutions (MDIs); RIN 3064-ZA18 (FDIC)

CBAI 2020 Federal Policy Priorities - Community Bank Response to the COVID-19 Crisis COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) The banking regulators have almost completed implementing S. 2155 so community banks can benefit from all of the regulatory relief measures. Community bankers, the associations that represent their interests, and Congress (which represent this vital economic constituency) must diligently insist on the swift completion the rulemaking - consistent with Congressional intent. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs , SARs, tax exempt interest on agricultural and small business loans, and beneficial ownership reporting) to permit them to serve their customers and communities better and more efficiently. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purposes, blatantly abusing their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in and the playing field leveled for community banks. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, CFPB, OCC, FDIC, Federal Reserve) Legislation and Regulation - H.R. 133 - Consolidated Appropriations Act (116th Congress) and the CARES Act (Appropriate Sections) Regarding Troubled Debt Restructuring (TDR) and the Central Liquidity Facility (CLF) for credit unions (House) H.R. 133 - Consolidated Appropriations Act (116th Congress) and the CARES Act (Appropriate Sections) Regarding $325 billion for additional Paycheck Protection Program (PPP) loans, simplified PPP loan forgiveness for loans $150,000 and less, fully forgivable Economic Injury Disaster Loan (EIDL) advances and ending the EIDL debt trap, lender hold harmless provisions for relying on borrower documentation and certification, tax deductions for business expenses paid with PPP funds, provisions that a PPP lender shall only be responsible for paying fees to an agent for services for which the lender directly contracts with the agent - applies to all PPP Loans, and changing the structure of fees earned (House)

CBAI 2020 Federal Policy Priorities - Community Bank Response to the COVID-19 Crisis COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) The banking regulators have almost completed implementing S. 2155 so community banks can benefit from all of the regulatory relief measures. Community bankers, the associations that represent their interests, and Congress (which represent this vital economic constituency) must diligently insist on the swift completion the rulemaking - consistent with Congressional intent. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs , SARs, tax exempt interest on agricultural and small business loans, and beneficial ownership reporting) to permit them to serve their customers and communities better and more efficiently. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purposes, blatantly abusing their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce, because of the risks they pose to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole that excludes their holding companies from being supervised and regulated by the Federal Reserve must be closed. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in and the playing field leveled for community banks. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Modifying the FDICs Brokered Deposit Rule The FDIC proposed brokered deposit rule needs to be updated to reflect modern ways of gathering deposits and they should not be viewed unfavorably, and subject to unreasonable restrictions. A properly tailored brokered deposit rule will ensure that it does not place undue limits on the reasonable use of brokered deposits by community banks. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, it is a matter of public safety to have a safe harbor from federal sanctions for financial institutions that choose to serve legally-compliant cannabis-related business in states where cannabis is legal. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act of 2019 (H.R. 1595) which provides this legal safe harbor. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Recent and encouraging signs by the FDIC to approve de novo charter applications must continue and many new banks should be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. The Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Community Bank Positions on Emerging Issues OCC - Special Purpose Fintech National Bank (SPNBs) Fintech Charters The Office of Comptroller of the Currency (OCC) intends to issue special purpose national banking charters to Fintech companies. Fintechs cannot have the advantages of a national bank charter with limited requirements, regulations, and liability. FASB - Current Expected Credit Loss Model (CECL) Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. CFPB - Customer Data Sharing Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. CFPB - Small-Dollar Consumer Lending Appropriate action will be required, as the revised implementation of the rule unfolds to assure appropriate and responsible access to small dollar loans by consumers and to minimize any negative impact on community banks small-dollar consumer lending. CFPB - Small Business Data Collection Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks, and Section 1071 should either be repealed, or community banks should be provided with a meaningful exception. Federal Reserve - Modernize Reg CC Fraud losses are increasing at community banks and Reg CC needs to keep pace with the technology. All banks, credit unions, and others who utilize the payments system should be operating on the same level playing field when it comes to return reasons for fraud and acknowledging and communicating about fraud. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, CFPB, OCC, FDIC, Federal Reserve) Legislation and Regulation - H.R. 133 - Consolidated Appropriations Act (116th Congress) and the CARES Act (Appropriate Sections) Regarding Troubled Debt Restructuring (TDR) and the Central Liquidity Facility (CLF) for credit unions (House) H.R. 133 - Consolidated Appropriations Act (116th Congress) and the CARES Act (Appropriate Sections) Regarding the full restoration of Economic Injury Disaster Loan (EIDL) offsets against Paycheck Protection Program (PPP) loan forgiveness - aka the EIDL offset (House and Senate) H.R. 133 - Consolidated Appropriations Act (116th Congress) and the CARES Act (Appropriate Sections) Regarding lender origination fees in the Paycheck Protection Program (PPP) (House and Senate) H.R. 133 - Consolidated Appropriations Act (116th Congress) and the CARES Act (Appropriate Sections) Regarding $325 billion for additional Paycheck Protection Program (PPP) loans, simplified PPP loan forgiveness for loans $150,000 and less, fully forgivable Economic Injury Disaster Loan (EIDL) advances and ending the EIDL debt trap, lender hold harmless provisions for relying on borrower documentation and certification, tax deductions for business expenses paid with PPP funds, provisions that a PPP lender shall only be responsible for paying fees to an agent for services for which the lender directly contracts with the agent - applies to all PPP Loans, and changing the structure of fees earned (House) Letters - Comment Letter to the Federal Deposit Insurance Corporation (FDIC) regarding: Proposed Revisions to Statement of Policy Regarding Minority Depository Institutions (MDIs); RIN 3064-ZA18 (FDIC) Comment Letter to the Consumer Financial Protection Bureau (CFPB) regarding: Small Business Data Collection Rulemaking - Proposals Under Consideration (CFPB) Comment Letter to the OCC, Federal Reserve, FDIC and the CFPB regarding: Notice of Proposed Rulemaking - Role of Supervisory Guidance: OCC Docket ID OCC-2020-0005, Federal Reserve Docket No. R-1725 and RIN 7100-AF96, FDIC RIN 3064-AF32, and CFPB Docket No CFOP 2020-0033 (OCC, Federal Reserve, FDIC and CFPB) Action Alerts - Action Alert regarding the full restoration of Economic Injury Disaster Loan (EIDL) offsets against Paycheck Protection Program (PPP) loan forgiveness - aka the EIDL offset (House and Senate) Action Alert regarding - simplified PPP loan forgiveness with a $150K threshold, reversing the EIDL offset against PPP loans forgiveness, excluding PPP loans from asset for regulatory capital purposes, extending the TDR provisions through 2021, and making the 8% CBLR permanent for banks under $10 billion, in the next pandemic relief bill (House and Senate) Miscellaneous - Fraud and red flags in the Paycheck Protection Program (PPP) lending related to fintechs and the SBA delivery of Economic Injury Disaster Loan (EIDL) advances (House and Senate) Paycheck Protection Program (PPP) member polling results looking forward to a new pandemic relief bill (House and Senate, Federal Reserve, OCC, FDIC, CFPB) Closing the Industrial Loan Company (ILC) regulatory loophole for consolidate supervision by the Federal Reserve of ILC parent holding companies (House)

CBAI 2020 Federal Policy Priorities - Community Bank Response to the COVID-19 Crisis COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) The banking regulators have almost completed implementing S. 2155 so community banks can benefit from all of the regulatory relief measures. Community bankers, the associations that represent their interests, and Congress (which represent this vital economic constituency) must diligently insist on the swift completion the rulemaking - consistent with Congressional intent. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs , SARs, tax exempt interest on agricultural and small business loans, and beneficial ownership reporting) to permit them to serve their customers and communities better and more efficiently. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purposes, blatantly abusing their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in and the playing field leveled for community banks. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, it is a matter of public safety to have a safe harbor from federal sanctions for financial institutions that choose to serve legally-compliant cannabis-related business in states where cannabis is legal. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act of 2019 (H.R. 1595) which provides this legal safe harbor. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. The Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. The Community Bank Positions on Emerging Issues CFPB - Small Business Data Collection Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks, and Section 1071 should either be repealed, or community banks should be provided with a meaningful exception. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, CFPB, OCC, FDIC, Federal Reserve) Legislation and Regulation - H.R. 133 - Consolidated Appropriations Act (116th Congress) and the CARES Act (Appropriate Sections) Regarding the full restoration of Economic Injury Disaster Loan (EIDL) offsets against Paycheck Protection Program (PPP) loan forgiveness - aka the EIDL offset (House and Senate) H.R. 133 - Consolidated Appropriations Act (116th Congress) and the CARES Act (Appropriate Sections) Regarding lender origination fees in the Paycheck Protection Program (PPP) (House and Senate) H.R. 133 - Consolidated Appropriations Act (116th Congress) and the CARES Act (Appropriate Sections) Regarding $325 billion for additional Paycheck Protection Program (PPP) loans, simplified PPP loan forgiveness for loans $150,000 and less, fully forgivable Economic Injury Disaster Loan (EIDL) advances and ending the EIDL debt trap, lender hold harmless provisions for relying on borrower documentation and certification, tax deductions for business expenses paid with PPP funds, provisions that a PPP lender shall only be responsible for paying fees to an agent for services for which the lender directly contracts with the agent - applies to all PPP Loans, and changing the structure of fees earned (House) Letters - Comment Letter to the Consumer Financial Protection Bureau (CFPB) regarding: Small Business Data Collection Rulemaking - Proposals Under Consideration (CFPB) Action Alerts - Action Alert regarding the full restoration of Economic Injury Disaster Loan (EIDL) offsets against Paycheck Protection Program (PPP) loan forgiveness - aka the EIDL offset (House and Senate) Action Alert regarding - simplified PPP loan forgiveness with a $150K threshold, reversing the EIDL offset against PPP loans forgiveness, excluding PPP loans from asset for regulatory capital purposes, extending the TDR provisions through 2021, and making the 8% CBLR permanent for banks under $10 billion, in the next pandemic relief bill (House and Senate) Miscellaneous - Fraud and red flags in the Paycheck Protection Program (PPP) lending related to fintechs and the SBA delivery of Economic Injury Disaster Loan (EIDL) advances (House and Senate) Paycheck Protection Program (PPP) member polling results looking forward to a new pandemic relief bill (House and Senate, Federal Reserve, OCC, FDIC, CFPB)

CBAI 2020 Federal Policy Priorities - Community Bank Response to the COVID-19 Crisis COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) The banking regulators have almost completed implementing S. 2155 so community banks can benefit from all of the regulatory relief measures. Community bankers, the associations that represent their interests, and Congress (which represent this vital economic constituency) must diligently insist on the swift completion the rulemaking - consistent with Congressional intent. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs , SARs, tax exempt interest on agricultural and small business loans, and beneficial ownership reporting) to permit them to serve their customers and communities better and more efficiently. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purposes, blatantly abusing their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, it is a matter of public safety to have a safe harbor from federal sanctions for financial institutions that choose to serve legally-compliant cannabis-related business in states where cannabis is legal. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act of 2019 (H.R. 1595) which provides this legal safe harbor. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. The Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Community Bank Positions on Emerging Issues CFPB - Customer Data Sharing Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. CFPB - Small-Dollar Consumer Lending Appropriate action will be required, as the revised implementation of the rule unfolds to assure appropriate and responsible access to small dollar loans by consumers and to minimize any negative impact on community banks small-dollar consumer lending. Federal Reserve - Modernize Reg CC Fraud losses are increasing at community banks and Reg CC needs to keep pace with the technology. All banks, credit unions, and others who utilize the payments system should be operating on the same level playing field when it comes to return reasons for fraud and acknowledging and communicating about fraud. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, CFPB, OCC, FDIC, Federal Reserve)

CBAI 2020 Federal Policy Priorities - Community Bank Response to the COVID-19 Crisis COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) The banking regulators have almost completed implementing S. 2155 so community banks can benefit from all of the regulatory relief measures. Community bankers, the associations that represent their interests, and Congress (which represent this vital economic constituency) must diligently insist on the swift completion the rulemaking - consistent with Congressional intent. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs , SARs, tax exempt interest on agricultural and small business loans, and beneficial ownership reporting) to permit them to serve their customers and communities better and more efficiently. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purposes, blatantly abusing their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in and the playing field leveled for community banks. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, it is a matter of public safety to have a safe harbor from federal sanctions for financial institutions that choose to serve legally-compliant cannabis-related business in states where cannabis is legal. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act of 2019 (H.R. 1595) which provides this legal safe harbor. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Community Bank Positions on Emerging Issues CFPB - Small Business Data Collection Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks, and Section 1071 should either be repealed, or community banks should be provided with a meaningful exception. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, CFPB, OCC, FDIC, Federal Reserve) Legislation and Regulation - H.R. 133 - Consolidated Appropriations Act (116th Congress) and the CARES Act (Appropriate Sections) Regarding Troubled Debt Restructuring (TDR) and the Central Liquidity Facility (CLF) for credit unions (House) H.R. 133 - Consolidated Appropriations Act (116th Congress) and the CARES Act (Appropriate Sections) Regarding the full restoration of Economic Injury Disaster Loan (EIDL) offsets against Paycheck Protection Program (PPP) loan forgiveness - aka the EIDL offset (House and Senate) H.R. 133 - Consolidated Appropriations Act (116th Congress) and the CARES Act (Appropriate Sections) Regarding lender origination fees in the Paycheck Protection Program (PPP) (House and Senate) H.R. 133 - Consolidated Appropriations Act (116th Congress) and the CARES Act (Appropriate Sections) Regarding $325 billion for additional Paycheck Protection Program (PPP) loans, simplified PPP loan forgiveness for loans $150,000 and less, fully forgivable Economic Injury Disaster Loan (EIDL) advances and ending the EIDL debt trap, lender hold harmless provisions for relying on borrower documentation and certification, tax deductions for business expenses paid with PPP funds, provisions that a PPP lender shall only be responsible for paying fees to an agent for services for which the lender directly contracts with the agent - applies to all PPP Loans, and changing the structure of fees earned (House) Letters - Comment Letter to the Consumer Financial Protection Bureau (CFPB) regarding: Small Business Data Collection Rulemaking - Proposals Under Consideration (CFPB) Action Alerts - Action Alert regarding the full restoration of Economic Injury Disaster Loan (EIDL) offsets against Paycheck Protection Program (PPP) loan forgiveness - aka the EIDL offset (House and Senate) Action Alert regarding - simplified PPP loan forgiveness with a $150K threshold, reversing the EIDL offset against PPP loans forgiveness, excluding PPP loans from asset for regulatory capital purposes, extending the TDR provisions through 2021, and making the 8% CBLR permanent for banks under $10 billion, in the next pandemic relief bill (House and Senate) Miscellaneous - Fraud and red flags in the Paycheck Protection Program (PPP) lending related to fintechs and the SBA delivery of Economic Injury Disaster Loan (EIDL) advances (House and Senate) Paycheck Protection Program (PPP) member polling results looking forward to a new pandemic relief bill (House and Senate, Federal Reserve, OCC, FDIC, CFPB)

Community Bankers Association of Illinois 2020 Federal Policy Priorities - Support The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) Support Additional Meaningful Regulatory Relief for Community Banks Oppose Credit Unions Expanded Powers Close the Industrial Loan Company (ILC) Regulatory Loophole Oppose Farm Credit Systems Expanded Powers Support the Federal Reserves Role in Payments System Improvement Support Modernizing the Community Reinvestment Act (CRA) Modify the FDICs Brokered Deposit Rule Support Safe Harbor for Banking Cannabis-Related Businesses Support De Novo Community Bank Formation, the Dual Banking System and Charter Choice Support Sound Principles for GSE Reform Support the Federal Home Loan Banks Support Agriculture and Rural America Support Enhanced Data, Cyber and Payment Card Security (Data Security) Support Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Support the Community Bank Positions on Emerging Issues OCCs Special Purpose Fintech National Bank (SPNBs) Fintech Charters FASBs Current Expected Credit Loss Model CFPBs Customer Data Sharing CFPBs Small-Dollar Consumer Lending CFPB's Small Business Data Collection Federal Reserves Modernize Reg CC Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts (House, Senate, CFPB, OCC, FDIC, Federal Reserve, FHFA) Legislation and Regulation - S. 4117 - Paycheck Protection Small Business Forgiveness Act (All Sections) Regarding Paycheck Protection Program (PPP) loans of $150,000 and under qualifying for forgiveness with one-page application (Senate) H.R. 7777 - Paycheck Protection Small Business Forgiveness Act (All Sections) Regarding Paycheck Protection Program (PPP) loans of $150,000 and under provided automatic forgiveness (House) Closing the Industrial Loan Company (ILC) loophole - discussion draft of legislation (House) Closing the Industrial Loan Company (ILC) loophole - Wirecard AG and Wirecard Bank in Germany and similarities with U.S. ILCs and their holding companies (House) Community Bank top priorities for pandemic relief measures - 1) Cosponsor legislation in the Senate and House (S. 4117 and H.R. 7777), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less; 2) Allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses. (S. 3612/H.R. 6821); 3) Support local regions by raising the current bank-qualified municipal bond annual issuance limit to $50 million from $10 million to expedite low-cost funding for local projects; 4) Enact bank capital and accounting relief measures to support borrowers and lenders facing historically challenging circumstances by extending Troubled Debt Restructuring (TDR), suspending the Current Expected Credit Loss (CECL) requirements, and making the 8% Community Bank Leverage Ratio (CBLR) permanent for institutions of $10 billion or less in assets; 5) Create capacity for additional lending by requiring SBA to purchase PPP loan at par; 6) Create a liability safe harbor for businesses from COVID-19-related lawsuits; 7) Support rural America by allowing interest on loans secured by agricultural real estate or primary residences in rural communities to be tax-exempt (ECORA, S. 1641/H.R. 1872), providing direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhance USDA guaranteed lending programs; 8) Expand the Employee Retention Tax Credit (ERTC) created by the CARES Act (H.R. 6776); 9) Enact an Industrial Loan Company moratorium of at least three years on the FDICs approval of deposit insurance applications. (A three-year moratorium was included in the Dodd-Frank Act as an appropriate response to a highly uncertain economic environment); 10) Extend the QM patch to January 2022 to help avoid additional disruption to the housing market. (House and Senate) Second Initiative - Community Bank top priorities for pandemic relief measures - 1) Support Sen. Cramers legislation (S. 4117), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less-allowing business owners to focus on their businesses and the safety of their employees and customers (protections against fraud and misrepresentation still apply). 2) Support Sen. Kings legislation (S. 4171), which would require Treasury or SBA (not a third-party) to create an easy-to-use online loan forgiveness calculator to help clear up what is a very confusing and complex application process. This would ensure borrowers and lenders protection and accuracy. 3) Support Rep. Houlahans legislation (H.R. 7777), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less-allowing business owners to focus on their businesses and the safety of their employees and customers (protections against fraud and misrepresentation still apply). 4) Support Rep. Wagners legislation (H.R. 7413), which would require Treasury or SBA (not a third-party) to create an easy-to-use online loan forgiveness calculator to help clear up what is a very confusing and complex application process. This would ensure borrowers and lenders protection and accuracy. 5) Create capacity for additional lending by requiring SBA to purchase PPP loans at par (minus the amount that has been forgiven). 6) Ensure PPP loans are not included in regulatory asset threshold calculations. If PPP lending causes our assets to exceed certain thresholds, additional regulations and supervision are triggered, causing many community banks to face costly, burdensome and unintended consequences. 7) Support Sen. Cornyns legislation (S. 3612), which would allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses, as they ordinarily would. Without this, the value of a PPP loan is effectively reduced and tax preparation is unnecessarily cumbersome. 8) Support Rep. Holdings legislation (H.R. 6821), which would allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses, as they ordinarily would. Without this, the value of a PPP loan is effectively reduced and tax preparation is unnecessarily cumbersome. 9) Enact bank capital and accounting relief measures to support borrowers and lenders facing historically challenging circumstances by extending TDR, suspending CECL and making the 8% CBLR permanent for institutions of $10 billion or less in assets. Banks strong capitalization at the beginning of the crisis means that capital and accounting could be implemented without compromising safety and soundness. 10) Create a liability safe harbor for businesses from COVID-19-related lawsuits. Community banks and small businesses have every incentive to ensure the personal safety of their employees and customers. Fear of opportunistic class actions or other suits will inhibit the restoration of economic activity. 11) Support rural America by passing Rep. Watkinss ECORA Act (H.R. 1872), which exempts interest on most agricultural loans from taxable income (lowering interest rates for farmers, ranchers and rural homeowners), provides direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhances USDA guaranteed lending programs. (House, Senate) FHFA/Fannie/Freddie .50% residential mortgage guarantee fee increase with a September 1, 2020 implementation date (FHFA, Federal Reserve, OCC, House, Senate) S. 2939 - Eliminating Corporate Shadow Banking Act of 2019 (all Sections) Regarding closing the Industrial Loan Company loophole - consolidated holding company supervision by the Federal Reserve (Senate) Revised FDIC Guidelines for Appeals of Material Supervisory Determinations (FDIC) Letters - Comment Letter to the Federal Deposit Insurance Corporation (FDIC) regarding: Proposed Rule - Parent Companies of Industrial Banks and Industrial Loan Companies; RIN 3064-AF31 (FDIC, House, Federal Reserve) Addendum to Comment Letter to the Federal Deposit Insurance Corporation (FDIC) regarding: Proposed Rule - Parent Companies of Industrial Banks and Industrial Loan Companies; RIN 3064-AF31 (FDIC, House, Federal Reserve) Comment Letter to the National Credit Union Administration (NCUA) regarding: Subordinated Debt; Proposed Rule RIN 3133-AF08 (NCUA) Comment Letter to the Consumer Financial Protection Bureau (CFPB) regarding: Request for Information on Equal Credit Opportunity and Regulation B; Docket No CFPB-2020-0026 (CFPB) Action Alerts - Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate) Action Alert regarding FHFA/Fannie/Freddie .50% residential mortgage guarantee fee increase with a September 1, 2020 implementation date (House, Senate) #2 Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate) Miscellaneous - OCC proposal to issue payments charters (OCC) Beneficial ownership reporting regulatory relief (with FinCEN - not a community bank responsibility) (House) Postal Service financial services [banking] pilot program (House) Community Reinvestment Act (CRA) modernization (joint rulemaking) (House) Payments System Improvements (Federal Reserve FedNow Service) (House) FinCEN breach of information on Suspicious Activity Reports (SARs) (FDIC) Expiration of time to receive, and delivery of, Economic Impact Payments (EIPs) (House, Senate)

Community Bankers Association of Illinois 2020 Federal Policy Priorities - Support The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) Support Additional Meaningful Regulatory Relief for Community Banks Oppose Credit Unions Expanded Powers Oppose Farm Credit Systems Expanded Powers Support the Federal Reserves Role in Payments System Improvement Support Modernizing the Community Reinvestment Act (CRA) Support Agriculture and Rural America Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts (House, Senate, CFPB, OCC, FDIC, Federal Reserve, FHFA) Legislation and Regulation - Community Bank top priorities for pandemic relief measures - 1) Support local regions by raising the current bank-qualified municipal bond annual issuance limit to $50 million from $10 million to expedite low-cost funding for local projects; 2) Support rural America by allowing interest on loans secured by agricultural real estate or primary residences in rural communities to be tax-exempt (ECORA, S.1641/H.R. 1872), providing direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhance USDA guaranteed lending programs (House and Senate) Second Initiative - Community Bank top priorities for pandemic relief measures - 1) Support rural America by passing Rep. Watkinss ECORA Act (H.R. 1872), which exempts interest on most agricultural loans from taxable income (lowering interest rates for farmers, ranchers and rural homeowners), provides direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhances USDA guaranteed lending programs. (House, Senate) Letters - Comment Letter to the National Credit Union Administration (NCUA) regarding: Subordinated Debt; Proposed Rule RIN 3133-AF08 (NCUA) Action Alerts - Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate) #2 Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate) Miscellaneous - Community Reinvestment Act (CRA) modernization (joint rulemaking) (House) Payments System Improvements (Federal Reserve FedNow Service) (House)

Community Bankers Association of Illinois 2020 Federal Policy Priorities - Support The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) Support Additional Meaningful Regulatory Relief for Community Banks Oppose Credit Unions Expanded Powers Oppose Farm Credit Systems Expanded Powers Support the Federal Reserves Role in Payments System Improvement Support Modernizing the Community Reinvestment Act (CRA) Support Safe Harbor for Banking Cannabis-Related Businesses Support Agriculture and Rural America Support Enhanced Data, Cyber and Payment Card Security (Data Security) Support Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Support the Community Bank Positions on Emerging Issues CFPBs Customer Data Sharing CFPBs Small Business Data Collection Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts (House, Senate, CFPB, OCC, FDIC, Federal Reserve, FHFA) Legislation and Regulation - S. 4117 - Paycheck Protection Small Business Forgiveness Act (All Sections) Regarding Paycheck Protection Program (PPP) loans of $150,000 and under qualifying for forgiveness with one-page application (Senate) H.R. 7777 - Paycheck Protection Small Business Forgiveness Act (All Sections) Regarding Paycheck Protection Program (PPP) loans of $150,000 and under provided automatic forgiveness (House) Community Bank top priorities for pandemic relief measures - 1) Cosponsor legislation in the Senate and House (S. 4117 and H.R. 7777), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less; 2) Allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses. (S. 3612/H.R. 6821); 3) Enact bank capital and accounting relief measures to support borrowers and lenders facing historically challenging circumstances by extending Troubled Debt Restructuring (TDR), suspending the Current Expected Credit Loss (CECL) requirements, and making the 8% Community Bank Leverage Ratio (CBLR) permanent for institutions of $10 billion or less in assets; 4) Create capacity for additional lending by requiring SBA to purchase PPP loan at par; 5) Create a liability safe harbor for businesses from COVID-19-related lawsuits; 6) Support rural America by allowing interest on loans secured by agricultural real estate or primary residences in rural communities to be tax-exempt (ECORA, S.1641/H.R. 1872), providing direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhance USDA guaranteed lending programs; 7) Expand the Employee Retention Tax Credit (ERTC) created by the CARES Act (H.R. 6776) (House and Senate) Second Initiative - Community Bank top priorities for pandemic relief measures - 1) Support Sen. Cramers legislation (S. 4117), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less-allowing business owners to focus on their businesses and the safety of their employees and customers (protections against fraud and misrepresentation still apply). 2) Support Sen. Kings legislation (S. 4171), which would require Treasury or SBA (not a third-party) to create an easy-to-use online loan forgiveness calculator to help clear up what is a very confusing and complex application process. This would ensure borrowers and lenders protection and accuracy. 3) Support Rep. Houlahans legislation (H.R. 7777), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less-allowing business owners to focus on their businesses and the safety of their employees and customers (protections against fraud and misrepresentation still apply). 4) Support Rep. Wagners legislation (H.R. 7413), which would require Treasury or SBA (not a third-party) to create an easy-to-use online loan forgiveness calculator to help clear up what is a very confusing and complex application process. This would ensure borrowers and lenders protection and accuracy. 5) Create capacity for additional lending by requiring SBA to purchase PPP loans at par (minus the amount that has been forgiven). 6) Ensure PPP loans are not included in regulatory asset threshold calculations. If PPP lending causes our assets to exceed certain thresholds, additional regulations and supervision are triggered, causing many community banks to face costly, burdensome and unintended consequences. 7) Support Sen. Cornyns legislation (S. 3612), which would allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses, as they ordinarily would. Without this, the value of a PPP loan is effectively reduced and tax preparation is unnecessarily cumbersome. 8) Support Rep. Holdings legislation (H.R. 6821), which would allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses, as they ordinarily would. Without this, the value of a PPP loan is effectively reduced and tax preparation is unnecessarily cumbersome. 9) Enact bank capital and accounting relief measures to support borrowers and lenders facing historically challenging circumstances by extending TDR, suspending CECL and making the 8% CBLR permanent for institutions of $10 billion or less in assets. Banks strong capitalization at the beginning of the crisis means that capital and accounting could be implemented without compromising safety and soundness. 10) Create a liability safe harbor for businesses from COVID-19-related lawsuits. Community banks and small businesses have every incentive to ensure the personal safety of their employees and customers. Fear of opportunistic class actions or other suits will inhibit the restoration of economic activity. 11) Support rural America by passing Rep. Watkinss ECORA Act (H.R. 1872), which exempts interest on most agricultural loans from taxable income (lowering interest rates for farmers, ranchers and rural homeowners), provides direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhances USDA guaranteed lending programs. (House, Senate) Letters - Comment Letter to the National Credit Union Administration (NCUA) regarding: Subordinated Debt; Proposed Rule RIN 3133-AF08 (NCUA) Comment Letter to the Consumer Financial Protection Bureau (CFPB) regarding: Request for Information on Equal Credit Opportunity and Regulation B; Docket No CFPB-2020-0026 (CFPB) Action Alerts - Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate) #2 Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate) Miscellaneous - OCC proposal to issue payments charters (OCC) Beneficial ownership reporting regulatory relief (with FinCEN - not a community bank responsibility) (House) Postal Service financial services [banking] pilot program (House) Community Reinvestment Act (CRA) modernization (joint rulemaking) (House) Payments System Improvements (Federal Reserve FedNow Service) (House)

Community Bankers Association of Illinois 2020 Federal Policy Priorities - Support The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) Support Additional Meaningful Regulatory Relief for Community Banks Oppose Credit Unions Expanded Powers Oppose Farm Credit Systems Expanded Powers Support the Federal Reserves Role in Payments System Improvement Support Modernizing the Community Reinvestment Act (CRA) Support Safe Harbor for Banking Cannabis-Related Businesses Support Sound Principles for GSE Reform Support the Federal Home Loan Banks Support Agriculture and Rural America Support Enhanced Data, Cyber and Payment Card Security (Data Security) Support the Community Bank Positions on Emerging Issues CFPBs Customer Data Sharing CFPB's Small Business Data Collection Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts (House, Senate, CFPB, OCC, FDIC, Federal Reserve, FHFA) Legislation and Regulation - S. 4117 - Paycheck Protection Small Business Forgiveness Act (All Sections) Regarding Paycheck Protection Program (PPP) loans of $150,000 and under qualifying for forgiveness with one-page application (Senate) H.R. 7777 - Paycheck Protection Small Business Forgiveness Act (All Sections) Regarding Paycheck Protection Program (PPP) loans of $150,000 and under provided automatic forgiveness (House) Community Bank top priorities for pandemic relief measures - 1) Cosponsor legislation in the Senate and House (S. 4117 and H.R. 7777), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less; 2) Allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses. (S. 3612/H.R. 6821); 3) Support local regions by raising the current bank-qualified municipal bond annual issuance limit to $50 million from $10 million to expedite low-cost funding for local projects; 4) Enact bank capital and accounting relief measures to support borrowers and lenders facing historically challenging circumstances by extending Troubled Debt Restructuring (TDR), suspending the Current Expected Credit Loss (CECL) requirements, and making the 8% Community Bank Leverage Ratio (CBLR) permanent for institutions of $10 billion or less in assets; 5) Create capacity for additional lending by requiring SBA to purchase PPP loan at par; 6) Create a liability safe harbor for businesses from COVID-19-related lawsuits; 7) Support rural America by allowing interest on loans secured by agricultural real estate or primary residences in rural communities to be tax-exempt (ECORA, S. 1641/H.R. 1872), providing direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhance USDA guaranteed lending programs; 8) Expand the Employee Retention Tax Credit (ERTC) created by the CARES Act (H.R. 6776), 9) Extend the QM patch to January 2022 to help avoid additional disruption to the housing market. (House and Senate) Second Initiative - Community Bank top priorities for pandemic relief measures - 1) Support Sen. Cramers legislation (S. 4117), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less-allowing business owners to focus on their businesses and the safety of their employees and customers (protections against fraud and misrepresentation still apply). 2) Support Sen. Kings legislation (S. 4171), which would require Treasury or SBA (not a third-party) to create an easy-to-use online loan forgiveness calculator to help clear up what is a very confusing and complex application process. This would ensure borrowers and lenders protection and accuracy. 3) Support Rep. Houlahans legislation (H.R. 7777), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less-allowing business owners to focus on their businesses and the safety of their employees and customers (protections against fraud and misrepresentation still apply). 4) Support Rep. Wagners legislation (H.R. 7413), which would require Treasury or SBA (not a third-party) to create an easy-to-use online loan forgiveness calculator to help clear up what is a very confusing and complex application process. This would ensure borrowers and lenders protection and accuracy. 5) Create capacity for additional lending by requiring SBA to purchase PPP loans at par (minus the amount that has been forgiven). 6) Ensure PPP loans are not included in regulatory asset threshold calculations. If PPP lending causes our assets to exceed certain thresholds, additional regulations and supervision are triggered, causing many community banks to face costly, burdensome and unintended consequences. 7) Support Sen. Cornyns legislation (S. 3612), which would allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses, as they ordinarily would. Without this, the value of a PPP loan is effectively reduced and tax preparation is unnecessarily cumbersome. 8) Support Rep. Holdings legislation (H.R. 6821), which would allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses, as they ordinarily would. Without this, the value of a PPP loan is effectively reduced and tax preparation is unnecessarily cumbersome. 9) Enact bank capital and accounting relief measures to support borrowers and lenders facing historically challenging circumstances by extending TDR, suspending CECL and making the 8% CBLR permanent for institutions of $10 billion or less in assets. Banks strong capitalization at the beginning of the crisis means that capital and accounting could be implemented without compromising safety and soundness. 10) Create a liability safe harbor for businesses from COVID-19-related lawsuits. Community banks and small businesses have every incentive to ensure the personal safety of their employees and customers. Fear of opportunistic class actions or other suits will inhibit the restoration of economic activity. 11) Support rural America by passing Rep. Watkinss ECORA Act (H.R. 1872), which exempts interest on most agricultural loans from taxable income (lowering interest rates for farmers, ranchers and rural homeowners), provides direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhances USDA guaranteed lending programs. (House, Senate) Letters - Comment Letter to the National Credit Union Administration (NCUA) regarding: Subordinated Debt; Proposed Rule RIN 3133-AF08 (NCUA) Comment Letter to the Consumer Financial Protection Bureau (CFPB) regarding: Request for Information on Equal Credit Opportunity and Regulation B; Docket No CFPB-2020-0026 (CFPB) Action Alerts - Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate) #2 Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate) Miscellaneous - OCC proposal to issue payments charters (OCC) Beneficial ownership reporting regulatory relief (with FinCEN - not a community bank responsibility) (House) Postal Service financial services [banking] pilot program (House) Community Reinvestment Act (CRA) modernization (joint rulemaking) (House) Payments System Improvements (Federal Reserve FedNow Service) (House)

Community Bankers Association of Illinois 2020 Federal Policy Priorities - Support The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) Support Additional Meaningful Regulatory Relief for Community Banks Oppose Credit Unions Expanded Powers Oppose Farm Credit Systems Expanded Powers Support Modernizing the Community Reinvestment Act (CRA) Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts (House, Senate, CFPB, OCC, FDIC, Federal Reserve, FHFA) Legislation and Regulation - Community Bank top priorities for pandemic relief measures - 1) Allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses. (S. 3612/H.R. 6821); 2) Support local regions by raising the current bank-qualified municipal bond annual issuance limit to $50 million from $10 million to expedite low-cost funding for local projects; 3) Support rural America by allowing interest on loans secured by agricultural real estate or primary residences in rural communities to be tax-exempt (ECORA, S.1641/H.R. 1872), providing direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhance USDA guaranteed lending programs; 4) Expand the Employee Retention Tax Credit (ERTC) created by the CARES Act (H.R. 6776) (House and Senate) Second Initiative - Community Bank top priorities for pandemic relief measures - 1) Support Sen. Cornyns legislation (S. 3612), which would allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses, as they ordinarily would. Without this, the value of a PPP loan is effectively reduced and tax preparation is unnecessarily cumbersome. 2) Support Rep. Holdings legislation (H.R. 6821), which would allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses, as they ordinarily would. Without this, the value of a PPP loan is effectively reduced and tax preparation is unnecessarily cumbersome. 3) Support rural America by passing Rep. Watkinss ECORA Act (H.R. 1872), which exempts interest on most agricultural loans from taxable income (lowering interest rates for farmers, ranchers and rural homeowners), provides direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhances USDA guaranteed lending programs. (House, Senate) Letters - Comment Letter to the National Credit Union Administration (NCUA) regarding: Subordinated Debt; Proposed Rule RIN 3133-AF08 (NCUA) Action Alerts - Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate) #2 Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate) Miscellaneous - Community Reinvestment Act (CRA) modernization (joint rulemaking) (House)

Community Bankers Association of Illinois 2020 Federal Policy Priorities - Support The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) Support Additional Meaningful Regulatory Relief for Community Banks Oppose Credit Unions Expanded Powers Support the Federal Reserves Role in Payments System Improvement Support Modernizing the Community Reinvestment Act (CRA) Support Safe Harbor for Banking Cannabis-Related Businesses Support Sound Principles for GSE Reform Support the Federal Home Loan Banks Support Agriculture and Rural America Support Enhanced Data, Cyber and Payment Card Security (Data Security) Support Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Support the Community Bank Positions on Emerging Issues CFPBs Customer Data Sharing CFPBs Small-Dollar Consumer Lending Federal Reserves Modernize Reg CC Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts (House, Senate, CFPB, OCC, FDIC, Federal Reserve, FHFA) Legislation and Regulations - Community Bank top priorities for pandemic relief measures - 1) Support rural America by allowing interest on loans secured by agricultural real estate or primary residences in rural communities to be tax-exempt (ECORA, S.1641/H.R. 1872), providing direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhance USDA guaranteed lending programs; 2) Extend the QM patch to January 2022 to help avoid additional disruption to the housing market. (House and Senate) Second Initiative - Community Bank top priorities for pandemic relief measures - 1) Support rural America by passing Rep. Watkinss ECORA Act (H.R. 1872), which exempts interest on most agricultural loans from taxable income (lowering interest rates for farmers, ranchers and rural homeowners), provides direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhances USDA guaranteed lending programs. (House, Senate) FHFA/Fannie/Freddie .50% residential mortgage guarantee fee increase with a September 1, 2020 implementation date (FHFA, Federal Reserve, OCC, House, Senate) Letters - Comment Letter to the National Credit Union Administration (NCUA) regarding: Subordinated Debt; Proposed Rule RIN 3133-AF08 (NCUA) Comment Letter to the Consumer Financial Protection Bureau (CFPB) regarding: Request for Information on Equal Credit Opportunity and Regulation B; Docket No CFPB-2020-0026 (CFPB) Action Alerts - Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate) Action Alert regarding FHFA/Fannie/Freddie .50% residential mortgage guarantee fee increase with a September 1, 2020 implementation date (House, Senate) #2 Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate) Miscellaneous - OCC proposal to issue payments charters (OCC) Postal Service financial services [banking] pilot program (House) Community Reinvestment Act (CRA) modernization (joint rulemaking)(House) Payments System Improvements (Federal Reserve FedNow Service) (House) Expiration of time to receive, and delivery of, Economic Impact Payments (EIPs) (House, Senate)

Legislation and Regulation - Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - difference in taxing origination fee income from PPP loans between tax paying community banks and tax-exempt credit unions (House) Letters - Comment Letter to the Office of Comptroller of the Currency (OCC) regarding: Joint Notice of Proposed Rulemaking - Request for Comment on Community Reinvestment Act Regulations - Office of Comptroller of the Currency, Docker ID OCC-2018-0008 and RIN 1557-AE34; Federal Deposit Insurance Corporation, RIN 3064-AF22 (OCC and FDIC) Letter to House and Senate regarding Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - the process for submitting closed loans to the SBA, borrower forgiveness, submitting SBAs form 1502, amount of the loan to be forgiven, forgiveness calculator, percentage of proceeds used for payroll versus non-payroll expenses, consequences of not spending 75% of loan proceeds on payroll, what constitutes full-time staff and new hires, are payments made in the 8 week period limited to cash payroll versus accrued and the impact on forgiveness, form of proof or documentation to qualify for forgiveness, payroll and forgivable expenses for the self-employed, self-rental income qualifying for forgiveness, intended way to remit forgiveness amounts to lenders, difference in taxing origination fee income from PPP loans between tax paying community banks and tax-exempt credit unions, and eligibility for employee retention credit (ERC) (House and Senate) Comment Letter to the NCUA regarding proposed rule about combination transactions with non-credit unions, credit union asset acquisitions - RIN 3313-AF10 (NCUA) Action Alerts - Action Alert regarding NCUA proposal to increase transparency of credit unions acquiring community banks, allowing the largest credit unions to issue subordinated debt, holding hearings on credit unions weaponizing their tax-exempt status to purchase community banks (NCUA, House and Senate) Miscellaneous - Joint (OCC and FDIC) Notice of Proposed Rulemaking on Community Reinvestment Act [CRA] Regulations, the modernization of the CRA (House)

Legislation and Regulation - Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - interest rate below break-even, short PPP loan terms, restricted use of PPP loan proceeds, and lender liability, and a PPP related liquidity facility (Treasury, SBA, House, Senate and Federal Reserve) Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - lender participation in the PPP, general availability of SBA forms, access to the SBAs portal, obtaining log-in credentials, SBA forms to obtain approval to become certified, SBA website list of active SBA lenders, SBA website list of PPP lenders, SBA call center access, late release of rules prior to the PPP going live, confusion surrounding the guaranteed portion of the PPP loans, bank board members not eligible to apply for PPP loans at their bank, PPP related liquidity facility, access to the SBA for answers to questions about the PPP, conflicting messaging from the SBA, and consistent need for additional guidance from the SBA and Treasury on various aspects of the PPP (House and Senate) Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - SBA technology supporting the PPP including delays in accessing E-Tran and the Lender Gateway, additional funding for (replenishing) the PPP, allocation of 25% of future PPP funds for banks under $50 billion in assets, and the creation of a Federal Reserve facility to support lending by providing term financing backed by PPP loans (Treasury, SBA, Federal Reserve, House and Senate) Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - allocation of 25% of future PPP funds for banks under $50 billion in assets, more workable loan terms - interest rates below funding costs, more flexible timing for loan disbursements expanding the program to meet non-payroll expenses, lender safe harbor, and suspending the beneficial ownership rule for non-current customers (House and Senate) Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - allocation of future PPP funds for banks between $10 - $50 billion in assets, SBA system crashes, difficulty inputting loans, large bank preferential access to the SBA for inputting their loans, automated bots overwhelming SBA system, slow processing times to input loans, exhaustion of the under $10 billion in bank asset funding tranche, loan forgiveness, and payment of PPP fees to the originating bank (House, Senate, FDIC, OCC, Federal Reserve, CFPB) Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - difference in taxing origination fee income from PPP loans between tax paying community banks and tax-exempt credit unions (House) Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - requirement that 75% of loan proceeds must be spent on retaining payroll, straight-forward approach to loan forgiveness, loan forgiveness calculator, presumption of borrower compliance for loans of $1 million and under, and questions related to loan forgiveness (House and Senate) Letters - Comment Letter to the Office of Comptroller of the Currency (OCC) regarding: Joint Notice of Proposed Rulemaking - Request for Comment on Community Reinvestment Act Regulations - Office of Comptroller of the Currency, Docker ID OCC-2018-0008 and RIN 1557-AE34; Federal Deposit Insurance Corporation, RIN 3064-AF22 (OCC and FDIC) Letter to the Federal Deposit Insurance Corporation (FDIC), OCC and Federal Reserve regarding providing financial services to non-customers and the unbanked during the COVID-19 crisis (FDIC, OCC, Federal Reserve and House) Letter to House and Senate regarding Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - the process for submitting closed loans to the SBA, borrower forgiveness, submitting SBAs form 1502, amount of the loan to be forgiven, forgiveness calculator, percentage of proceeds used for payroll versus non-payroll expenses, consequences of not spending 75% of loan proceeds on payroll, what constitutes full-time staff and new hires, are payments made in the 8 week period limited to cash payroll versus accrued and the impact on forgiveness, form of proof or documentation to qualify for forgiveness, payroll and forgivable expenses for the self-employed, self-rental income qualifying for forgiveness, intended way to remit forgiveness amounts to lenders, difference in taxing origination fee income from PPP loans between tax paying community banks and tax-exempt credit unions, and eligibility for employee retention credit (ERC) (House and Senate) Letter to House and Senate regarding Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - flexible spending of loan proceeds - 75%/25% split, flexible options for the 8 week period to spend funds, presumption of borrower compliance for loans under $1 million, easy to apply approach to loan forgiveness, loan forgiveness calculator, streamline form for self-employed and independent contractors, and preserve payroll and other business expense deductions for PPP loan recipients (House and Senate) Comment Letter to the NCUA regarding proposed rule about combination transactions with non-credit unions, credit union asset acquisitions - RIN 3313-AF10 (NCUA) Action Alerts - Action Alert regarding replenishing the SBAs small business loan fund (PPP) (Phase 2) (House and Senate) Action Alert regarding fixing various problems with the SBAs PPP (House and Senate) Action Alert regarding recommendations for improvement and answers to questions about the SBAs PPP loans (House and Senate) Action Alert regarding passing necessary SBA PPP reforms (Senate and House) Action Alert regarding NCUA proposal to increase transparency of credit unions acquiring community banks, allowing the largest credit unions to issue subordinated debt, holding hearings on credit unions weaponizing their tax-exempt status to purchase community banks (NCUA, House and Senate) Miscellaneous - Joint (OCC and FDIC) Notice of Proposed Rulemaking on Community Reinvestment Act [CRA] Regulations, the modernization of the CRA (House) On-line lender versus community bank lender performance during the COVID-10 crisis (House and Senate)

Letters - Comment Letter to the Office of Comptroller of the Currency (OCC) regarding: Joint Notice of Proposed Rulemaking - Request for Comment on Community Reinvestment Act Regulations - Office of Comptroller of the Currency, Docker ID OCC-2018-0008 and RIN 1557-AE34; Federal Deposit Insurance Corporation, RIN 3064-AF22 (OCC and FDIC) Letter to the Federal Deposit Insurance Corporation (FDIC), OCC and Federal Reserve regarding providing financial services to non-customers and the unbanked during the COVID-19 crisis (FDIC, OCC, Federal Reserve and House) Comment Letter to the NCUA regarding proposed rule about combination transactions with non-credit unions, credit union asset acquisitions - RIN 3313-AF10 (NCUA) Action Alerts - Action Alert regarding NCUA proposal to increase transparency of credit unions acquiring community banks, allowing the largest credit unions to issue subordinated debt, holding hearings on credit unions weaponizing their tax-exempt status to purchase community banks (NCUA, House and Senate) Miscellaneous - Joint (OCC and FDIC) Notice of Proposed Rulemaking on Community Reinvestment Act [CRA] Regulations, the modernization of the CRA (House)

Legislation and Regulation - Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - interest rate below break-even, short PPP loan terms, restricted use of PPP loan proceeds, and lender liability, and a PPP related liquidity facility (Treasury, SBA, House, Senate and Federal Reserve) Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - lender participation in the PPP, general availability of SBA forms, access to the SBAs portal, obtaining log-in credentials, SBA forms to obtain approval to become certified, SBA website list of active SBA lenders, SBA website list of PPP lenders, SBA call center access, late release of rules prior to the PPP going live, confusion surrounding the guaranteed portion of the PPP loans, bank board members not eligible to apply for PPP loans at their bank, PPP related liquidity facility, access to the SBA for answers to questions about the PPP, conflicting messaging from the SBA, and consistent need for additional guidance from the SBA and Treasury on various aspects of the PPP (House and Senate) Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - SBA technology supporting the PPP including delays in accessing E-Tran and the Lender Gateway, additional funding for (replenishing) the PPP, allocation of 25% of future PPP funds for banks under $50 billion in assets, and the creation of a Federal Reserve facility to support lending by providing term financing backed by PPP loans (Treasury, SBA, Federal Reserve, House and Senate) Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - allocation of 25% of future PPP funds for banks under $50 billion in assets, more workable loan terms - interest rates below funding costs, more flexible timing for loan disbursements expanding the program to meet non-payroll expenses, lender safe harbor, and suspending the beneficial ownership rule for non-current customers (House and Senate) Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - allocation of future PPP funds for banks between $10 - $50 billion in assets, SBA system crashes, difficulty inputting loans, large bank preferential access to the SBA for inputting their loans, automated bots overwhelming SBA system, slow processing times to input loans, exhaustion of the under $10 billion in bank asset funding tranche, loan forgiveness, and payment of PPP fees to the originating bank (House, Senate, FDIC, OCC, Federal Reserve, CFPB) Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - difference in taxing origination fee income from PPP loans between tax paying community banks and tax-exempt credit unions (House) Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - requirement that 75% of loan proceeds must be spent on retaining payroll, straight-forward approach to loan forgiveness, loan forgiveness calculator, presumption of borrower compliance for loans of $1 million and under, and questions related to loan forgiveness (House and Senate) Letters - Comment Letter to the Office of Comptroller of the Currency (OCC) regarding: Joint Notice of Proposed Rulemaking - Request for Comment on Community Reinvestment Act Regulations - Office of Comptroller of the Currency, Docker ID OCC-2018-0008 and RIN 1557-AE34; Federal Deposit Insurance Corporation, RIN 3064-AF22 (OCC and FDIC) Letter to the Federal Deposit Insurance Corporation (FDIC), OCC and Federal Reserve regarding providing financial services to non-customers and the unbanked during the COVID-19 crisis (FDIC, OCC, Federal Reserve and House) Letter to House and Senate regarding Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - the process for submitting closed loans to the SBA, borrower forgiveness, submitting SBAs form 1502, amount of the loan to be forgiven, forgiveness calculator, percentage of proceeds used for payroll versus non-payroll expenses, consequences of not spending 75% of loan proceeds on payroll, what constitutes full-time staff and new hires, are payments made in the 8 week period limited to cash payroll versus accrued and the impact on forgiveness, form of proof or documentation to qualify for forgiveness, payroll and forgivable expenses for the self-employed, self-rental income qualifying for forgiveness, intended way to remit forgiveness amounts to lenders, difference in taxing origination fee income from PPP loans between tax paying community banks and tax-exempt credit unions, and eligibility for employee retention credit (ERC) (House and Senate) Letter to House and Senate regarding Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - flexible spending of loan proceeds - 75%/25% split, flexible options for the 8 week period to spend funds, presumption of borrower compliance for loans under $1 million, easy to apply approach to loan forgiveness, loan forgiveness calculator, streamline form for self-employed and independent contractors, and preserve payroll and other business expense deductions for PPP loan recipients (House and Senate) Comment Letter to the NCUA regarding proposed rule about combination transactions with non-credit unions, credit union asset acquisitions - RIN 3313-AF10 (NCUA) Action Alerts - Action Alert regarding replenishing the SBAs small business loan fund (PPP) (Phase 2) (House and Senate) Action Alert regarding fixing various problems with the SBAs PPP (House and Senate) Action Alert regarding recommendations for improvement and answers to questions about the SBAs PPP loans (House and Senate) Action Alert regarding passing necessary SBA PPP reforms (Senate and House) Action Alert regarding NCUA proposal to increase transparency of credit unions acquiring community banks, allowing the largest credit unions to issue subordinated debt, holding hearings on credit unions weaponizing their tax-exempt status to purchase community banks (NCUA, House and Senate) Miscellaneous - Joint (OCC and FDIC) Notice of Proposed Rulemaking on Community Reinvestment Act [CRA] Regulations, the modernization of the CRA (House) On-line lender versus community bank lender performance during the COVID-10 crisis (House and Senate)

Legislation and Regulation - Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - interest rate below break-even, short PPP loan terms, restricted use of PPP loan proceeds, and lender liability, and a PPP related liquidity facility (Treasury, SBA, House, Senate and Federal Reserve) Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - lender participation in the PPP, general availability of SBA forms, access to the SBAs portal, obtaining log-in credentials, SBA forms to obtain approval to become certified, SBA website list of active SBA lenders, SBA website list of PPP lenders, SBA call center access, late release of rules prior to the PPP going live, confusion surrounding the guaranteed portion of the PPP loans, bank board members not eligible to apply for PPP loans at their bank, PPP related liquidity facility, access to the SBA for answers to questions about the PPP, conflicting messaging from the SBA, and consistent need for additional guidance from the SBA and Treasury on various aspects of the PPP (House and Senate) Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - SBA technology supporting the PPP including delays in accessing E-Tran and the Lender Gateway, additional funding for (replenishing) the PPP, allocation of 25% of future PPP funds for banks under $50 billion in assets, and the creation of a Federal Reserve facility to support lending by providing term financing backed by PPP loans (Treasury, SBA, Federal Reserve, House and Senate) Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - allocation of 25% of future PPP funds for banks under $50 billion in assets, more workable loan terms - interest rates below funding costs, more flexible timing for loan disbursements expanding the program to meet non-payroll expenses, lender safe harbor, and suspending the beneficial ownership rule for non-current customers (House and Senate) Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - allocation of future PPP funds for banks between $10 - $50 billion in assets, SBA system crashes, difficulty inputting loans, large bank preferential access to the SBA for inputting their loans, automated bots overwhelming SBA system, slow processing times to input loans, exhaustion of the under $10 billion in bank asset funding tranche, loan forgiveness, and payment of PPP fees to the originating bank (House, Senate, FDIC, OCC, Federal Reserve, CFPB) Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - difference in taxing origination fee income from PPP loans between tax paying community banks and tax-exempt credit unions (House) Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - requirement that 75% of loan proceeds must be spent on retaining payroll, straight-forward approach to loan forgiveness, loan forgiveness calculator, presumption of borrower compliance for loans of $1 million and under, and questions related to loan forgiveness (House and Senate) Letters - Comment Letter to the Office of Comptroller of the Currency (OCC) regarding: Joint Notice of Proposed Rulemaking - Request for Comment on Community Reinvestment Act Regulations - Office of Comptroller of the Currency, Docker ID OCC-2018-0008 and RIN 1557-AE34; Federal Deposit Insurance Corporation, RIN 3064-AF22 (OCC and FDIC) Letter to the Federal Deposit Insurance Corporation (FDIC), OCC and Federal Reserve regarding providing financial services to non-customers and the unbanked during the COVID-19 crisis (FDIC, OCC, Federal Reserve and House) Letter to House and Senate regarding Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - the process for submitting closed loans to the SBA, borrower forgiveness, submitting SBAs form 1502, amount of the loan to be forgiven, forgiveness calculator, percentage of proceeds used for payroll versus non-payroll expenses, consequences of not spending 75% of loan proceeds on payroll, what constitutes full-time staff and new hires, are payments made in the 8 week period limited to cash payroll versus accrued and the impact on forgiveness, form of proof or documentation to qualify for forgiveness, payroll and forgivable expenses for the self-employed, self-rental income qualifying for forgiveness, intended way to remit forgiveness amounts to lenders, difference in taxing origination fee income from PPP loans between tax paying community banks and tax-exempt credit unions, and eligibility for employee retention credit (ERC) (House and Senate) Letter to House and Senate regarding Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation - flexible spending of loan proceeds - 75%/25% split, flexible options for the 8 week period to spend funds, presumption of borrower compliance for loans under $1 million, easy to apply approach to loan forgiveness, loan forgiveness calculator, streamline form for self-employed and independent contractors, and preserve payroll and other business expense deductions for PPP loan recipients (House and Senate) Comment Letter to the NCUA regarding proposed rule about combination transactions with non-credit unions, credit union asset acquisitions - RIN 3313-AF10 (NCUA) Comment letter to the FDIC regarding unsafe and unsound banking practices, brokered deposit restrictions - RIN 3064-AE94 Comment Letter to the Federal Housing Finance Agency (FHFA) regarding request for information about membership eligibility in Federal Home Loan Banks (FHFA) Comment Letter to the FDIC regarding proposed rule about parent companies of industrial banks and industrial loan companies (ILCs), RIN 3064-AF31 (FDIC and House) Action Alerts - Action Alert regarding replenishing the SBAs small business loan fund (PPP) (Phase 2) (House and Senate) Action Alert regarding fixing various problems with the SBAs PPP (House and Senate) Action Alert regarding recommendations for improvement and answers to questions about the SBAs PPP loans (House and Senate) Action Alert regarding easing proposed brokered deposit restrictions (FDIC) Action Alert regarding passing necessary SBA PPP reforms (Senate and House) Action Alert regarding NCUA proposal to increase transparency of credit unions acquiring community banks, allowing the largest credit unions to issue subordinated debt, holding hearings on credit unions weaponizing their tax-exempt status to purchase community banks (NCUA, House and Senate) Miscellaneous - Joint (OCC and FDIC) Notice of Proposed Rulemaking on Community Reinvestment Act [CRA] Regulations, the modernization of the CRA (House) Closing the Industrial Loan Company (ILC) loophole (House) On-line lender versus community bank lender performance during the COVID-10 crisis (House and Senate)

CBAI Federal Policy Priorities - 2019 The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. The Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country. The swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018. The passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. Credit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders. The United States payments system (System), which is the very foundation of our financial services and economy, must be modernized to meet the demands of consumers and to keep pace with the rest of the world. System improvements must not be dominated by the largest banks and financial firms or private-sector non-banks. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system which requires the Federal Reserve to continue to play a preeminent role in the Systems improvement. The Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks). The recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, OCC) Legislation - SAFE Banking Act (H.R. 1595 and S. 1200) (All Sections), cannabis banking safe harbor (House, Senate, OCC) Enhances Credit Opportunities in Rural America (ECORA) (H.R. 1872 and S.1641) (All Sections), interest earned on agricultural real estate and rural single family home loans would not be taxable (House, Senate, OCC) Letters - None Action Alerts - Action Alert regarding tax-exempt credit unions purchasing taxpaying community banks and Congressional oversight of credit unions (House, Senate) Miscellaneous - Modernization of the CRA, OCC Comment Letter - Reforming the CRA Regulatory Framework, Docket ID OCC-2018-0008 and RIN 1557-AE34 (House) Modernization of the CRA (OCC) Tax-exempt credit unions purchasing taxpaying community banks (House and Senate, OCC) Rural America and Farm Credit System lenders (House, Senate, OCC) Community bank response to Coronavirus (House, Senate)

CBAI Federal Policy Priorities - 2019 The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. The Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country. The swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018. The passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. Credit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders. The Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks). The recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, OCC) Legislation - SAFE Banking Act (H.R. 1595 and S. 1200) (All Sections), cannabis banking safe harbor (House, Senate, OCC) Enhances Credit Opportunities in Rural America (ECORA) (H.R. 1872 and S.1641) (All Sections), interest earned on agricultural real estate and rural single family home loans would not be taxable (House, Senate, OCC) Letters - None Action Alerts - Action Alert regarding tax-exempt credit unions purchasing taxpaying community banks and Congressional oversight of credit unions (House, Senate) Miscellaneous - Modernization of the CRA, OCC Comment Letter - Reforming the CRA Regulatory Framework, Docket ID OCC-2018-0008 and RIN 1557-AE34 (House) Modernization of the CRA (OCC) Tax-exempt credit unions purchasing taxpaying community banks (House and Senate, OCC) Rural America and Farm Credit System lenders (House, Senate, OCC) Community bank response to Coronavirus (House, Senate)

CBAI Federal Policy Priorities - 2019 The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. The Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country. The swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018. The passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. Credit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders. The United States payments system (System), which is the very foundation of our financial services and economy, must be modernized to meet the demands of consumers and to keep pace with the rest of the world. System improvements must not be dominated by the largest banks and financial firms or private-sector non-banks. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system which requires the Federal Reserve to continue to play a preeminent role in the Systems improvement. The Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks). The reform of the housing GSEs remains critically important to the future of the housing market and the U.S. economy. American homeowners have benefited from the critical role Fannie Mae and Freddie Mac have played in helping finance homeownership for many decades. The GSEs have provided a steady, reliable source of funding for home mortgage lending through all economic cycles and in all markets. Community banks depend on the GSEs for direct access to the secondary market without having to sell their loans through larger financial institutions that compete with them. The GSEs allow community banks to retain the servicing of the loans they sell, which helps to keep delinquencies and foreclosures low. And, unlike other private investors or aggregators, the GSEs have a mandate to serve all markets at all times which is critical to maintaining liquidity when the markets are experiencing financial stress. Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable and reliable sources of funding for their members . However, given their unique relationship with thousands of community lenders, it may be appropriate for the FHLBs to support their members secondary market activities as aggregators or guarantors for residential mortgage loans, provided their current ability to serve their members is not impeded or threatened. Additionally, the FHFA should not impose an ongoing housing mission asset test on FHLB membership, which would undermine the reliability of FHLB funding. Community banks are strong guardians of the security and confidentiality of their customers information and are on the frontline of defending against cyber security threats. Core data security principals in legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants in the payment system should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; a national data security breach and notification standard should replace the current patchwork of state laws; and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations, only to achieve the same superior results they currently attain. Regulations promulgated by the Consumer Financial Protection Bureau CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. The CFPB should not be unduly influencing marketplace behavior by targeting financial institutions, products, services, and practices which it deems to be undesirable or inappropriate regardless of what consumers want. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB, in the Dodd-Frank Act (Section 1022(b)(3)(A), has the statutory authority to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. There is an emerging threat to the security of consumer data from the proliferation of companies seeking to access bank customer account information (i.e., customer data sharing). The Consumer Financial Protection Bureau (CFPB) is responsible under the Dodd-Frank Act to promulgate this rule. While community banks support responsible innovation in financial products and services, the integrity of consumer data and privacy is only as strong as the weakest link. Community banks are financially sound and take great care in protecting consumer privacy, but non-bank entities are typically not well capitalized, have no significant assets and are financially unable to make restitution in the event of a loss. They must none-the-less be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. The Consumer Financial Protection Bureaus (CFPB) small-dollar lending rule was intended to address its concerns about consumer abuse caused by payday and vehicle title lenders. The proposed rule was too broadly drafted and would have ensnared sensible community bank small-dollar consumer lending. Some exemptions were granted for community banks after a burdensome rulemaking process. Subsequently, the new CFPB Director proposed eliminating the underwriting provision, and the delay in the payment provision was continued by a U.S. District Judge. A carefully monitoring and appropriate action will be required, as the implementation of the rule unfolds, to minimize any negative impact on community banks small-dollar consumer lending. The recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, OCC) Legislation - SAFE Banking Act (H.R. 1595 and S. 1200) (All Sections), cannabis banking safe harbor (House, Senate, OCC) Enhances Credit Opportunities in Rural America (ECORA) (H.R. 1872 and S.1641) (All Sections), interest earned on agricultural real estate and rural single family home loans would not be taxable (House, Senate, OCC) Letters - Comment Letter to the Office of the Comptroller of the Currency (OCC) regarding Permissible Interest on Loans that are Sold, Assigned, or Otherwise Transferred; Docket ID OCC-2019-0027 and RIN 1557-AE73 (OCC) Comment Letter to the Consumer Financial Protection Bureau (CFPB) regarding Request for Information Regarding the Integrated Mortgage Disclosure Under the Real Estate Settlement Procedures Act (Regulation X) and the Truth in Lending Act (Regulation (Z) Rule Assessment; Docket No. CFPB-2019-0055 (CFPB) Action Alerts - Action Alert regarding tax-exempt credit unions purchasing taxpaying community banks and Congressional oversight of credit unions (House, Senate) Miscellaneous - Modernization of the CRA, OCC Comment Letter - Reforming the CRA Regulatory Framework, Docket ID OCC-2018-0008 and RIN 1557-AE34 (House) Modernization of the CRA (OCC) Tax-exempt credit unions purchasing taxpaying community banks (House and Senate, OCC) Rural America and Farm Credit System lenders (House, Senate, OCC) Community bank response to Coronavirus (House, Senate)

CBAI Federal Policy Priorities - 2019 The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. The Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country. The swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018. The passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. Credit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders. The United States payments system (System), which is the very foundation of our financial services and economy, must be modernized to meet the demands of consumers and to keep pace with the rest of the world. System improvements must not be dominated by the largest banks and financial firms or private-sector non-banks. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system which requires the Federal Reserve to continue to play a preeminent role in the Systems improvement. The Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks). Community banks are strong guardians of the security and confidentiality of their customers information and are on the frontline of defending against cyber security threats. Core data security principals in legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants in the payment system should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; a national data security breach and notification standard should replace the current patchwork of state laws; and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations, only to achieve the same superior results they currently attain. There is an emerging threat to the security of consumer data from the proliferation of companies seeking to access bank customer account information (i.e., customer data sharing). The Consumer Financial Protection Bureau (CFPB) is responsible under the Dodd-Frank Act to promulgate this rule. While community banks support responsible innovation in financial products and services, the integrity of consumer data and privacy is only as strong as the weakest link. Community banks are financially sound and take great care in protecting consumer privacy, but non-bank entities are typically not well capitalized, have no significant assets and are financially unable to make restitution in the event of a loss. They must none-the-less be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. While community banks represent less than 20% of banking industry assets, they make 60% of the small business loans and 80% of agricultural loans. The requirement for reporting small business data collection stems from Section 1071 of the Dodd-Frank Act and is meant to facilitate the enforcement of fair lending laws in small business lending. The data, however, clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks that lack scale and compliance resources, and Section 1071 should either be repealed or community banks should be provided with a meaningful exception. The recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, OCC) Legislation - SAFE Banking Act (H.R. 1595 and S. 1200) (All Sections), cannabis banking safe harbor (House, Senate, OCC) Enhances Credit Opportunities in Rural America (ECORA) (H.R. 1872 and S.1641) (All Sections), interest earned on agricultural real estate and rural single family home loans would not be taxable (House, Senate, OCC) Corporate Transparency Act of 2019 and Coordinating Oversight/Illicit Cash Act (H.R. 2513&14 and S. 2563) (All Sections), which amends the Bank Secrecy Act (BSA) to require beneficial ownership information to be collected by the Financial Crimes Enforcement Network (FinCEN) (House, Senate, OCC) Preserving Small Business Lending Act of 2020 (H.R. 5574) (All Sections), regarding Section 1071 of the Dodd-Frank Act about small business data collection (House, Senate, OCC) Letters - Comment Letter to the Office of the Comptroller of the Currency (OCC) regarding Permissible Interest on Loans that are Sold, Assigned, or Otherwise Transferred; Docket ID OCC-2019-0027 and RIN 1557-AE73 (OCC) Action Alerts - Action Alert regarding tax-exempt credit unions purchasing taxpaying community banks and Congressional oversight of credit unions (House, Senate) Miscellaneous - Modernization of the CRA, OCC Comment Letter - Reforming the CRA Regulatory Framework, Docket ID OCC-2018-0008 and RIN 1557-AE34 (House) Modernization of the CRA (OCC) Tax-exempt credit unions purchasing taxpaying community banks (House and Senate, OCC) Rural America and Farm Credit System lenders (House, Senate, OCC) Community bank response to Coronavirus (House, Senate)

CBAI Federal Policy Priorities - 2019 The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. The Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country. The swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018. The passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. Credit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders. The United States payments system (System), which is the very foundation of our financial services and economy, must be modernized to meet the demands of consumers and to keep pace with the rest of the world. System improvements must not be dominated by the largest banks and financial firms or private-sector non-banks. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system which requires the Federal Reserve to continue to play a preeminent role in the Systems improvement. The Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks). The reform of the housing GSEs remains critically important to the future of the housing market and the U.S. economy. American homeowners have benefited from the critical role Fannie Mae and Freddie Mac have played in helping finance homeownership for many decades. The GSEs have provided a steady, reliable source of funding for home mortgage lending through all economic cycles and in all markets. Community banks depend on the GSEs for direct access to the secondary market without having to sell their loans through larger financial institutions that compete with them. The GSEs allow community banks to retain the servicing of the loans they sell, which helps to keep delinquencies and foreclosures low. And, unlike other private investors or aggregators, the GSEs have a mandate to serve all markets at all times which is critical to maintaining liquidity when the markets are experiencing financial stress. Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable and reliable sources of funding for their members . However, given their unique relationship with thousands of community lenders, it may be appropriate for the FHLBs to support their members secondary market activities as aggregators or guarantors for residential mortgage loans, provided their current ability to serve their members is not impeded or threatened. Additionally, the FHFA should not impose an ongoing housing mission asset test on FHLB membership, which would undermine the reliability of FHLB funding. A vibrant agricultural and rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from further cuts or adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Community banks are strong guardians of the security and confidentiality of their customers information and are on the frontline of defending against cyber security threats. Core data security principals in legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants in the payment system should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; a national data security breach and notification standard should replace the current patchwork of state laws; and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations, only to achieve the same superior results they currently attain. While community banks represent less than 20% of banking industry assets, they make 60% of the small business loans and 80% of agricultural loans. The requirement for reporting small business data collection stems from Section 1071 of the Dodd-Frank Act and is meant to facilitate the enforcement of fair lending laws in small business lending. The data, however, clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks that lack scale and compliance resources, and Section 1071 should either be repealed or community banks should be provided with a meaningful exception. The recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, OCC) Legislation - SAFE Banking Act (H.R. 1595 and S. 1200) (All Sections), cannabis banking safe harbor (House, Senate, OCC) Enhances Credit Opportunities in Rural America (ECORA) (H.R. 1872 and S.1641) (All Sections), interest earned on agricultural real estate and rural single family home loans would not be taxable (House, Senate, OCC) Corporate Transparency Act of 2019 and Coordinating Oversight/Illicit Cash Act (H.R. 2513&14 and S. 2563) (All Sections), which amends the Bank Secrecy Act (BSA) to require beneficial ownership information to be collected by the Financial Crimes Enforcement Network (FinCEN) (House, Senate, OCC) Preserving Small Business Lending Act of 2020 (H.R. 5574) (All Sections), regarding Section 1071 of the Dodd-Frank Act about small business data collection (House, Senate, OCC) Letters - Letter to The Honorable Senator Mike D. Crapo regarding request for information about Concerns with Cannabis Banking Legislation (Senate) Comment Letter to the Office of the Comptroller of the Currency (OCC) regarding Permissible Interest on Loans that are Sold, Assigned, or Otherwise Transferred; Docket ID OCC-2019-0027 and RIN 1557-AE73 (OCC) Action Alerts - Action Alert regarding tax-exempt credit unions purchasing taxpaying community banks and Congressional oversight of credit unions (House, Senate) Miscellaneous - Modernization of the CRA, OCC Comment Letter - Reforming the CRA Regulatory Framework, Docket ID OCC-2018-0008 and RIN 1557-AE34 (House) Modernization of the CRA (OCC) Tax-exempt credit unions purchasing taxpaying community banks (House and Senate, OCC) Rural America and Farm Credit System lenders (House, Senate, OCC) Community bank response to Coronavirus (House, Senate)

CBAI Federal Policy Priorities - 2019 The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. The Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country. The swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018. The passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. Credit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders. The United States payments system (System), which is the very foundation of our financial services and economy, must be modernized to meet the demands of consumers and to keep pace with the rest of the world. System improvements must not be dominated by the largest banks and financial firms or private-sector non-banks. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system which requires the Federal Reserve to continue to play a preeminent role in the Systems improvement. The Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks). The Federal Deposit Insurance Corporation (FDIC) Deposit Rate Caps (Rate Caps) impact community banks ability to grow and thrive. The flaws in how the Rate Caps are calculated include: not reflecting competitive funding or investment opportunities; the largest banks extensive branch networks and their too-big-to-fail subsidies have an outsized influence on the Rate Caps; promotional and negotiated rates are excluded which present an incomplete picture of the deposit-rate landscape; and credit unions are omitted which wrongly ignores thousands of financial institutions that are similar to community banks. Also, during safety and soundness examinations for well capitalized banks, FDIC examiners are using the flawed Rate Caps as a benchmark in the analysis of bank liquidity, which inevitably results in faulty conclusions that can impact liquidity in a banks CAMELS rating. Without taking a position on the legalization of cannabis, it is a matter of public safety to have a safe harbor from federal sanctions for financial institutions that choose to serve legally-compliant cannabis-related business in states where cannabis is legal. Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant banking profession in the face of industry consolidation. The Federal Deposit Insurance Corporation (FDIC) has indicated a change in direction to finally get back on the right course. These encouraging signs must be closely monitored to assure that many new banks are chartered each year to help maintain the vitality of the community banking profession. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, which has served our nation well for over 150 years, where chartering and supervision is divided between the federal government and the states. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances on the immense power of the regulators, as well as improved rulemaking - as the benefit of each agencies expertise and experience is brought to bear on complex and controversial issues. The reform of the housing GSEs remains critically important to the future of the housing market and the U.S. economy. American homeowners have benefited from the critical role Fannie Mae and Freddie Mac have played in helping finance homeownership for many decades. The GSEs have provided a steady, reliable source of funding for home mortgage lending through all economic cycles and in all markets. Community banks depend on the GSEs for direct access to the secondary market without having to sell their loans through larger financial institutions that compete with them. The GSEs allow community banks to retain the servicing of the loans they sell, which helps to keep delinquencies and foreclosures low. And, unlike other private investors or aggregators, the GSEs have a mandate to serve all markets at all times which is critical to maintaining liquidity when the markets are experiencing financial stress. Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable and reliable sources of funding for their members . However, given their unique relationship with thousands of community lenders, it may be appropriate for the FHLBs to support their members secondary market activities as aggregators or guarantors for residential mortgage loans, provided their current ability to serve their members is not impeded or threatened. Additionally, the FHFA should not impose an ongoing housing mission asset test on FHLB membership, which would undermine the reliability of FHLB funding. A vibrant agricultural and rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from further cuts or adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Community banks are strong guardians of the security and confidentiality of their customers information and are on the frontline of defending against cyber security threats. Core data security principals in legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants in the payment system should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; a national data security breach and notification standard should replace the current patchwork of state laws; and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations, only to achieve the same superior results they currently attain. Regulations promulgated by the Consumer Financial Protection Bureau CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. The CFPB should not be unduly influencing marketplace behavior by targeting financial institutions, products, services, and practices which it deems to be undesirable or inappropriate regardless of what consumers want. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB, in the Dodd-Frank Act (Section 1022(b)(3)(A), has the statutory authority to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Office of Comptroller of the Currency (OCC) intends to issue special purpose national banking charters to Fintech companies. The OCCs intentions, however, raise many concerns. The very legal authority permitting the OCC to charter Fintechs has been challenged by the Conference of State Bank Supervisors (CSBS) as being fatally flawed. A single regulator acting unilaterally in the chartering, examining, supervising and regulating Fintechs is not in the best interests of the profession, consumers and the economy. Congress must provide the explicit statutory authority to charter Fintechs. If the OCC moves forward, it must guarantee that Fintechs will comply with all banking laws, rules and regulations, and that they be held to the same rigorous safety and soundness standards (e.g., supervision and regulation) that are currently being required of community banks and bank holding companies. Fintechs cannot have the advantages of a national bank charter with limited requirements, regulations and liability. The Financial Accounting Standards Board (FASB) has approved significant revisions to the way community banks reserve for their loan losses (i.e., the Current Expected Credit Loss (CECL) Model). After significant community banker input, FASB agreed to address community banker concerns and revised their Model proposal. The revised CECL is more flexible and scalable for community banks by allowing them to evaluate and adjust loan loss amounts using qualitative factors, historic losses, and their current operating systems such as spreadsheets, narratives and other noncomplex estimation methods. Community bankers and Congress must continue to be vigilant to assure the Model implementation provides a clear, practical and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. There is an emerging threat to the security of consumer data from the proliferation of companies seeking to access bank customer account information (i.e., customer data sharing). The Consumer Financial Protection Bureau (CFPB) is responsible under the Dodd-Frank Act to promulgate this rule. While community banks support responsible innovation in financial products and services, the integrity of consumer data and privacy is only as strong as the weakest link. Community banks are financially sound and take great care in protecting consumer privacy, but non-bank entities are typically not well capitalized, have no significant assets and are financially unable to make restitution in the event of a loss. They must none-the-less be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. The Consumer Financial Protection Bureaus (CFPB) small-dollar lending rule was intended to address its concerns about consumer abuse caused by payday and vehicle title lenders. The proposed rule was too broadly drafted and would have ensnared sensible community bank small-dollar consumer lending. Some exemptions were granted for community banks after a burdensome rulemaking process. Subsequently, the new CFPB Director proposed eliminating the underwriting provision, and the delay in the payment provision was continued by a U.S. District Judge. A carefully monitoring and appropriate action will be required, as the implementation of the rule unfolds, to minimize any negative impact on community banks small-dollar consumer lending. While community banks represent less than 20% of banking industry assets, they make 60% of the small business loans and 80% of agricultural loans. The requirement for reporting small business data collection stems from Section 1071 of the Dodd-Frank Act and is meant to facilitate the enforcement of fair lending laws in small business lending. The data, however, clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks that lack scale and compliance resources, and Section 1071 should either be repealed or community banks should be provided with a meaningful exception. Fraud losses are increasing at community banks and Reg CC needs to keep pace with the technology that banks and their customers are using, both now and particularly as the payments system transitions to real-time. All banks, credit unions, and others who utilize the payments system should be operating on the same level playing field when it comes to return reasons for fraud and acknowledging and communicating about fraud. The recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, OCC) Legislation - Proposed legislation to amend the Bank Holding Company Act to regulate industrial bank holding companies (House, Senate, OCC) SAFE Banking Act (H.R. 1595 and S. 1200) (All Sections), cannabis banking safe harbor (House, Senate, OCC) Enhances Credit Opportunities in Rural America (ECORA) (H.R. 1872 and S.1641) (All Sections), interest earned on agricultural real estate and rural single family home loans would not be taxable (House, Senate, OCC) Community Bank Access to Capital (S.1233) (All Sections), exempting banks under certain thresholds from Sarbanes-Oxley internal control attestations and FDIC annual reports, and revises the SECs definition of investor categories (House, Senate, OCC) Corporate Transparency Act of 2019 and Coordinating Oversight/Illicit Cash Act (H.R. 2513&14 and S. 2563) (All Sections), which amends the Bank Secrecy Act (BSA) to require beneficial ownership information to be collected by the Financial Crimes Enforcement Network (FinCEN) (House, Senate, OCC) Preserving Small Business Lending Act of 2020 (H.R. 5574) (All Sections), regarding Section 1071 of the Dodd-Frank Act about small business data collection (House, Senate, OCC) Letters - Letter to The Honorable Senator Mike D. Crapo regarding request for information about Concerns with Cannabis Banking Legislation (Senate) Comment Letter to the Office of the Comptroller of the Currency (OCC) regarding Permissible Interest on Loans that are Sold, Assigned, or Otherwise Transferred; Docket ID OCC-2019-0027 and RIN 1557-AE73 (OCC) Comment Letter to the Consumer Financial Protection Bureau (CFPB) regarding Request for Information Regarding the Integrated Mortgage Disclosure Under the Real Estate Settlement Procedures Act (Regulation X) and the Truth in Lending Act (Regulation (Z) Rule Assessment; Docket No. CFPB-2019-0055 (CFPB) Letter to the Federal Deposit Insurance Corporation (FDIC) regarding Deposit Insurance Applications for Industrial Loan Companies (FDIC, House) Action Alerts - Action Alert regarding tax-exempt credit unions purchasing taxpaying community banks and Congressional oversight of credit unions (House, Senate) Miscellaneous - Modernization of the CRA, OCC Comment Letter - Reforming the CRA Regulatory Framework, Docket ID OCC-2018-0008 and RIN 1557-AE34 (House) Modernization of the CRA (OCC) Tax-exempt credit unions purchasing taxpaying community banks (House and Senate, OCC) Rural America and Farm Credit System lenders (House, Senate, OCC) Community bank response to Coronavirus (House, Senate) Federal Reserves potential removal of Wells Fargo Asset Cap. (House) Current Expected Credit Loss (CECL) model (OCC)

CBAI Federal Policy Priorities - 2019 The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. The Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country. The swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018. The passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. Credit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders. The United States payments system (System), which is the very foundation of our financial services and economy, must be modernized to meet the demands of consumers and to keep pace with the rest of the world. System improvements must not be dominated by the largest banks and financial firms or private-sector non-banks. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system which requires the Federal Reserve to continue to play a preeminent role in the Systems improvement. The Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks). The reform of the housing GSEs remains critically important to the future of the housing market and the U.S. economy. American homeowners have benefited from the critical role Fannie Mae and Freddie Mac have played in helping finance homeownership for many decades. The GSEs have provided a steady, reliable source of funding for home mortgage lending through all economic cycles and in all markets. Community banks depend on the GSEs for direct access to the secondary market without having to sell their loans through larger financial institutions that compete with them. The GSEs allow community banks to retain the servicing of the loans they sell, which helps to keep delinquencies and foreclosures low. And, unlike other private investors or aggregators, the GSEs have a mandate to serve all markets at all times which is critical to maintaining liquidity when the markets are experiencing financial stress. Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable and reliable sources of funding for their members . However, given their unique relationship with thousands of community lenders, it may be appropriate for the FHLBs to support their members secondary market activities as aggregators or guarantors for residential mortgage loans, provided their current ability to serve their members is not impeded or threatened. Additionally, the FHFA should not impose an ongoing housing mission asset test on FHLB membership, which would undermine the reliability of FHLB funding. Community banks are strong guardians of the security and confidentiality of their customers information and are on the frontline of defending against cyber security threats. Core data security principals in legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants in the payment system should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; a national data security breach and notification standard should replace the current patchwork of state laws; and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations, only to achieve the same superior results they currently attain. Regulations promulgated by the Consumer Financial Protection Bureau CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. The CFPB should not be unduly influencing marketplace behavior by targeting financial institutions, products, services, and practices which it deems to be undesirable or inappropriate regardless of what consumers want. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB, in the Dodd-Frank Act (Section 1022(b)(3)(A), has the statutory authority to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. There is an emerging threat to the security of consumer data from the proliferation of companies seeking to access bank customer account information (i.e., customer data sharing). The Consumer Financial Protection Bureau (CFPB) is responsible under the Dodd-Frank Act to promulgate this rule. While community banks support responsible innovation in financial products and services, the integrity of consumer data and privacy is only as strong as the weakest link. Community banks are financially sound and take great care in protecting consumer privacy, but non-bank entities are typically not well capitalized, have no significant assets and are financially unable to make restitution in the event of a loss. They must none-the-less be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. The Consumer Financial Protection Bureaus (CFPB) small-dollar lending rule was intended to address its concerns about consumer abuse caused by payday and vehicle title lenders. The proposed rule was too broadly drafted and would have ensnared sensible community bank small-dollar consumer lending. Some exemptions were granted for community banks after a burdensome rulemaking process. Subsequently, the new CFPB Director proposed eliminating the underwriting provision, and the delay in the payment provision was continued by a U.S. District Judge. A carefully monitoring and appropriate action will be required, as the implementation of the rule unfolds, to minimize any negative impact on community banks small-dollar consumer lending. The recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, OCC, CFPB) Legislation - Enhances Credit Opportunities in Rural America (ECORA) (H.R. 1872 and S.1641) (All Sections), interest earned on agricultural real estate and rural single family home loans would not be taxable (House and Senate, OCC, CFPB) Letters - Comment Letter to the Department of Housing and Urban Development (HUD) regarding HUDs implementation of the Fair Housing Acts Disparate Impact standard; Docket No FR-6111-P-02 and RIN 2529-AA98 (HUD) Comment Letter to the National Credit Union Administration (NCUA) regarding proposed rule about serving core-based/urban statistical areas (NCUA) Action Alerts - Action Alert regarding proposal to increase the Home Mortgage Disclosure Act (HMDA) thresholds for collecting and reporting data (CFPB) Action Alert regarding the National Credit Union Administration (NCUA) proposed rule about serving core-based/urban statistical areas (NCUA) Miscellaneous - Tax-exempt credit unions purchasing taxpaying community banks (House and Senate, OCC, CFPB)

CBAI Federal Policy Priorities - 2019 The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. The Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country. The swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018. The passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. Credit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders. The United States payments system (System), which is the very foundation of our financial services and economy, must be modernized to meet the demands of consumers and to keep pace with the rest of the world. System improvements must not be dominated by the largest banks and financial firms or private-sector non-banks. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system which requires the Federal Reserve to continue to play a preeminent role in the Systems improvement. The Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks). The Federal Deposit Insurance Corporation (FDIC) Deposit Rate Caps (Rate Caps) impact community banks ability to grow and thrive. The flaws in how the Rate Caps are calculated include: not reflecting competitive funding or investment opportunities; the largest banks extensive branch networks and their too-big-to-fail subsidies have an outsized influence on the Rate Caps; promotional and negotiated rates are excluded which present an incomplete picture of the deposit-rate landscape; and credit unions are omitted which wrongly ignores thousands of financial institutions that are similar to community banks. Also, during safety and soundness examinations for well capitalized banks, FDIC examiners are using the flawed Rate Caps as a benchmark in the analysis of bank liquidity, which inevitably results in faulty conclusions that can impact liquidity in a banks CAMELS rating. Without taking a position on the legalization of cannabis, it is a matter of public safety to have a safe harbor from federal sanctions for financial institutions that choose to serve legally-compliant cannabis-related business in states where cannabis is legal. Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant banking profession in the face of industry consolidation. The Federal Deposit Insurance Corporation (FDIC) has indicated a change in direction to finally get back on the right course. These encouraging signs must be closely monitored to assure that many new banks are chartered each year to help maintain the vitality of the community banking profession. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, which has served our nation well for over 150 years, where chartering and supervision is divided between the federal government and the states. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances on the immense power of the regulators, as well as improved rulemaking - as the benefit of each agencies expertise and experience is brought to bear on complex and controversial issues. The reform of the housing GSEs remains critically important to the future of the housing market and the U.S. economy. American homeowners have benefited from the critical role Fannie Mae and Freddie Mac have played in helping finance homeownership for many decades. The GSEs have provided a steady, reliable source of funding for home mortgage lending through all economic cycles and in all markets. Community banks depend on the GSEs for direct access to the secondary market without having to sell their loans through larger financial institutions that compete with them. The GSEs allow community banks to retain the servicing of the loans they sell, which helps to keep delinquencies and foreclosures low. And, unlike other private investors or aggregators, the GSEs have a mandate to serve all markets at all times which is critical to maintaining liquidity when the markets are experiencing financial stress. Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable and reliable sources of funding for their members . However, given their unique relationship with thousands of community lenders, it may be appropriate for the FHLBs to support their members secondary market activities as aggregators or guarantors for residential mortgage loans, provided their current ability to serve their members is not impeded or threatened. Additionally, the FHFA should not impose an ongoing housing mission asset test on FHLB membership, which would undermine the reliability of FHLB funding. A vibrant agricultural and rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from further cuts or adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Community banks are strong guardians of the security and confidentiality of their customers information and are on the frontline of defending against cyber security threats. Core data security principals in legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants in the payment system should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; a national data security breach and notification standard should replace the current patchwork of state laws; and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations, only to achieve the same superior results they currently attain. Regulations promulgated by the Consumer Financial Protection Bureau CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. The CFPB should not be unduly influencing marketplace behavior by targeting financial institutions, products, services, and practices which it deems to be undesirable or inappropriate regardless of what consumers want. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB, in the Dodd-Frank Act (Section 1022(b)(3)(A), has the statutory authority to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Office of Comptroller of the Currency (OCC) intends to issue special purpose national banking charters to Fintech companies. The OCCs intentions, however, raise many concerns. The very legal authority permitting the OCC to charter Fintechs has been challenged by the Conference of State Bank Supervisors (CSBS) as being fatally flawed. A single regulator acting unilaterally in the chartering, examining, supervising and regulating Fintechs is not in the best interests of the profession, consumers and the economy. Congress must provide the explicit statutory authority to charter Fintechs. If the OCC moves forward, it must guarantee that Fintechs will comply with all banking laws, rules and regulations, and that they be held to the same rigorous safety and soundness standards (e.g., supervision and regulation) that are currently being required of community banks and bank holding companies. Fintechs cannot have the advantages of a national bank charter with limited requirements, regulations and liability. The Financial Accounting Standards Board (FASB) has approved significant revisions to the way community banks reserve for their loan losses (i.e., the Current Expected Credit Loss (CECL) Model). After significant community banker input, FASB agreed to address community banker concerns and revised their Model proposal. The revised CECL is more flexible and scalable for community banks by allowing them to evaluate and adjust loan loss amounts using qualitative factors, historic losses, and their current operating systems such as spreadsheets, narratives and other noncomplex estimation methods. Community bankers and Congress must continue to be vigilant to assure the Model implementation provides a clear, practical and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. There is an emerging threat to the security of consumer data from the proliferation of companies seeking to access bank customer account information (i.e., customer data sharing). The Consumer Financial Protection Bureau (CFPB) is responsible under the Dodd-Frank Act to promulgate this rule. While community banks support responsible innovation in financial products and services, the integrity of consumer data and privacy is only as strong as the weakest link. Community banks are financially sound and take great care in protecting consumer privacy, but non-bank entities are typically not well capitalized, have no significant assets and are financially unable to make restitution in the event of a loss. They must none-the-less be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. The Consumer Financial Protection Bureaus (CFPB) small-dollar lending rule was intended to address its concerns about consumer abuse caused by payday and vehicle title lenders. The proposed rule was too broadly drafted and would have ensnared sensible community bank small-dollar consumer lending. Some exemptions were granted for community banks after a burdensome rulemaking process. Subsequently, the new CFPB Director proposed eliminating the underwriting provision, and the delay in the payment provision was continued by a U.S. District Judge. A carefully monitoring and appropriate action will be required, as the implementation of the rule unfolds, to minimize any negative impact on community banks small-dollar consumer lending. While community banks represent less than 20% of banking industry assets, they make 60% of the small business loans and 80% of agricultural loans. The requirement for reporting small business data collection stems from Section 1071 of the Dodd-Frank Act and is meant to facilitate the enforcement of fair lending laws in small business lending. The data, however, clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks that lack scale and compliance resources, and Section 1071 should either be repealed or community banks should be provided with a meaningful exception. Fraud losses are increasing at community banks and Reg CC needs to keep pace with the technology that banks and their customers are using, both now and particularly as the payments system transitions to real-time. All banks, credit unions, and others who utilize the payments system should be operating on the same level playing field when it comes to return reasons for fraud and acknowledging and communicating about fraud. The recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, OCC, Federal Reserve, CFPB) Legislation - Enhances Credit Opportunities in Rural America (ECORA) (H.R. 1872 and S.1641) (All Sections), interest earned on agricultural real estate and rural single family home loans would not be taxable (House and Senate, OCC, CFPB) Community Bank Access to Capital (S.1233) (All Sections), exempting banks under certain thresholds from Sarbanes-Oxley internal control attestations and FDIC annual reports, and revises the SECs definition of investor categories (House and Senate, OCC, CFPB) Corporate Transparency Act of 2019 (H.R. 2513) (All Sections), which amends the Bank Secrecy Act (BSA) to require beneficial ownership information to be collected by the Financial Crimes Enforcement Network (FinCEN) (House) Letters - Comment Letter to the Department of Housing and Urban Development (HUD) regarding HUDs implementation of the Fair Housing Acts Disparate Impact standard; Docket No FR-6111-P-02 and RIN 2529-AA98 (HUD) Comment Letter to the Federal Deposit Insurance Corporation (FDIC) regarding interest rate restrictions on institutions that are less than well capitalized (Deposit Rate Caps); RIN 3064-AF02 (FDIC) Comment Letter to the Federal Reserve regarding Notice and Request for Comments - Federal Reserve actions to support interbank settlement of faster payments [FedNow Service] (Federal Reserve) Comment Letter to the National Credit Union Administration (NCUA) regarding proposed rule about serving core-based/urban statistical areas (NCUA) Action Alerts - Action Alert regarding proposal to increase the Home Mortgage Disclosure Act (HMDA) thresholds for collecting and reporting data (CFPB) Action Alert regarding the Corporate Transparency Act of 2019 (H.R. 2513) (all Sections), which amends the Bank Secrecy Act (BSA) to require beneficial ownership information to be collected by the Financial Crimes Enforcement Network (FinCEN) (House) Action Alert regarding the Federal Reserves implementation of its FedNow (faster payments) Service (Federal Reserve) Action Alert regarding the National Credit Union Administration (NCUA) proposed rule about serving core-based/urban statistical areas (NCUA) Miscellaneous - Tax-exempt credit unions purchasing taxpaying community banks (House and Senate, OCC, CFPB) FDIC Listening Session on Supervisory Appeals and Dispute Resolution Process (FDIC) Closing the supervisory loophole for Industrial Loan Corporations (ILCs) (House)

CBAI Federal Policy Priorities - 2019 The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. The Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country. The swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018. The passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. Credit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders. The United States payments system (System), which is the very foundation of our financial services and economy, must be modernized to meet the demands of consumers and to keep pace with the rest of the world. System improvements must not be dominated by the largest banks and financial firms or private-sector non-banks. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system which requires the Federal Reserve to continue to play a preeminent role in the Systems improvement. The Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks). Community banks are strong guardians of the security and confidentiality of their customers information and are on the frontline of defending against cyber security threats. Core data security principals in legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants in the payment system should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; a national data security breach and notification standard should replace the current patchwork of state laws; and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations, only to achieve the same superior results they currently attain. There is an emerging threat to the security of consumer data from the proliferation of companies seeking to access bank customer account information (i.e., customer data sharing). The Consumer Financial Protection Bureau (CFPB) is responsible under the Dodd-Frank Act to promulgate this rule. While community banks support responsible innovation in financial products and services, the integrity of consumer data and privacy is only as strong as the weakest link. Community banks are financially sound and take great care in protecting consumer privacy, but non-bank entities are typically not well capitalized, have no significant assets and are financially unable to make restitution in the event of a loss. They must none-the-less be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. While community banks represent less than 20% of banking industry assets, they make 60% of the small business loans and 80% of agricultural loans. The requirement for reporting small business data collection stems from Section 1071 of the Dodd-Frank Act and is meant to facilitate the enforcement of fair lending laws in small business lending. The data, however, clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks that lack scale and compliance resources, and Section 1071 should either be repealed or community banks should be provided with a meaningful exception. The recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, OCC, CFPB) Legislation - Enhances Credit Opportunities in Rural America (ECORA) (H.R. 1872 and S.1641) (All Sections), interest earned on agricultural real estate and rural single family home loans would not be taxable (House and Senate, OCC, CFPB) Corporate Transparency Act of 2019 (H.R. 2513) (all Sections), which amends the Bank Secrecy Act (BSA) to require beneficial ownership information to be collected by the Financial Crimes Enforcement Network (FinCEN) (House) Letters - Comment Letter to the National Credit Union Administration (NCUA) regarding proposed rule about serving core-based/urban statistical areas (NCUA) Action Alerts - Action Alert regarding the Corporate Transparency Act of 2019 (H.R. 2513) (all Sections), which amends the Bank Secrecy Act (BSA) to require beneficial ownership information to be collected by the Financial Crimes Enforcement Network (FinCEN) (House) Action Alert regarding the National Credit Union Administration (NCUA) proposed rule about serving core-based/urban statistical areas (NCUA) Miscellaneous - Tax-exempt credit unions purchasing taxpaying community banks (House and Senate, OCC, CFPB)

CBAI Federal Policy Priorities - 2019 The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. The Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country. The swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018. The passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. Credit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders. The United States payments system (System), which is the very foundation of our financial services and economy, must be modernized to meet the demands of consumers and to keep pace with the rest of the world. System improvements must not be dominated by the largest banks and financial firms or private-sector non-banks. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system which requires the Federal Reserve to continue to play a preeminent role in the Systems improvement. The Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks). The Federal Deposit Insurance Corporation (FDIC) Deposit Rate Caps (Rate Caps) impact community banks ability to grow and thrive. The flaws in how the Rate Caps are calculated include: not reflecting competitive funding or investment opportunities; the largest banks extensive branch networks and their too-big-to-fail subsidies have an outsized influence on the Rate Caps; promotional and negotiated rates are excluded which present an incomplete picture of the deposit-rate landscape; and credit unions are omitted which wrongly ignores thousands of financial institutions that are similar to community banks. Also, during safety and soundness examinations for well capitalized banks, FDIC examiners are using the flawed Rate Caps as a benchmark in the analysis of bank liquidity, which inevitably results in faulty conclusions that can impact liquidity in a banks CAMELS rating. Without taking a position on the legalization of cannabis, it is a matter of public safety to have a safe harbor from federal sanctions for financial institutions that choose to serve legally-compliant cannabis-related business in states where cannabis is legal. Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant banking profession in the face of industry consolidation. The Federal Deposit Insurance Corporation (FDIC) has indicated a change in direction to finally get back on the right course. These encouraging signs must be closely monitored to assure that many new banks are chartered each year to help maintain the vitality of the community banking profession. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, which has served our nation well for over 150 years, where chartering and supervision is divided between the federal government and the states. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances on the immense power of the regulators, as well as improved rulemaking - as the benefit of each agencies expertise and experience is brought to bear on complex and controversial issues. The reform of the housing GSEs remains critically important to the future of the housing market and the U.S. economy. American homeowners have benefited from the critical role Fannie Mae and Freddie Mac have played in helping finance homeownership for many decades. The GSEs have provided a steady, reliable source of funding for home mortgage lending through all economic cycles and in all markets. Community banks depend on the GSEs for direct access to the secondary market without having to sell their loans through larger financial institutions that compete with them. The GSEs allow community banks to retain the servicing of the loans they sell, which helps to keep delinquencies and foreclosures low. And, unlike other private investors or aggregators, the GSEs have a mandate to serve all markets at all times which is critical to maintaining liquidity when the markets are experiencing financial stress. Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable and reliable sources of funding for their members . However, given their unique relationship with thousands of community lenders, it may be appropriate for the FHLBs to support their members secondary market activities as aggregators or guarantors for residential mortgage loans, provided their current ability to serve their members is not impeded or threatened. Additionally, the FHFA should not impose an ongoing housing mission asset test on FHLB membership, which would undermine the reliability of FHLB funding. A vibrant agricultural and rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from further cuts or adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Community banks are strong guardians of the security and confidentiality of their customers information and are on the frontline of defending against cyber security threats. Core data security principals in legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants in the payment system should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; a national data security breach and notification standard should replace the current patchwork of state laws; and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations, only to achieve the same superior results they currently attain. Regulations promulgated by the Consumer Financial Protection Bureau CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. The CFPB should not be unduly influencing marketplace behavior by targeting financial institutions, products, services, and practices which it deems to be undesirable or inappropriate regardless of what consumers want. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB, in the Dodd-Frank Act (Section 1022(b)(3)(A), has the statutory authority to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Office of Comptroller of the Currency (OCC) intends to issue special purpose national banking charters to Fintech companies. The OCCs intentions, however, raise many concerns. The very legal authority permitting the OCC to charter Fintechs has been challenged by the Conference of State Bank Supervisors (CSBS) as being fatally flawed. A single regulator acting unilaterally in the chartering, examining, supervising and regulating Fintechs is not in the best interests of the profession, consumers and the economy. Congress must provide the explicit statutory authority to charter Fintechs. If the OCC moves forward, it must guarantee that Fintechs will comply with all banking laws, rules and regulations, and that they be held to the same rigorous safety and soundness standards (e.g., supervision and regulation) that are currently being required of community banks and bank holding companies. Fintechs cannot have the advantages of a national bank charter with limited requirements, regulations and liability. The Financial Accounting Standards Board (FASB) has approved significant revisions to the way community banks reserve for their loan losses (i.e., the Current Expected Credit Loss (CECL) Model). After significant community banker input, FASB agreed to address community banker concerns and revised their Model proposal. The revised CECL is more flexible and scalable for community banks by allowing them to evaluate and adjust loan loss amounts using qualitative factors, historic losses, and their current operating systems such as spreadsheets, narratives and other noncomplex estimation methods. Community bankers and Congress must continue to be vigilant to assure the Model implementation provides a clear, practical and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. There is an emerging threat to the security of consumer data from the proliferation of companies seeking to access bank customer account information (i.e., customer data sharing). The Consumer Financial Protection Bureau (CFPB) is responsible under the Dodd-Frank Act to promulgate this rule. While community banks support responsible innovation in financial products and services, the integrity of consumer data and privacy is only as strong as the weakest link. Community banks are financially sound and take great care in protecting consumer privacy, but non-bank entities are typically not well capitalized, have no significant assets and are financially unable to make restitution in the event of a loss. They must none-the-less be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. The Consumer Financial Protection Bureaus (CFPB) small-dollar lending rule was intended to address its concerns about consumer abuse caused by payday and vehicle title lenders. The proposed rule was too broadly drafted and would have ensnared sensible community bank small-dollar consumer lending. Some exemptions were granted for community banks after a burdensome rulemaking process. Subsequently, the new CFPB Director proposed eliminating the underwriting provision, and the delay in the payment provision was continued by a U.S. District Judge. A carefully monitoring and appropriate action will be required, as the implementation of the rule unfolds, to minimize any negative impact on community banks small-dollar consumer lending. While community banks represent less than 20% of banking industry assets, they make 60% of the small business loans and 80% of agricultural loans. The requirement for reporting small business data collection stems from Section 1071 of the Dodd-Frank Act and is meant to facilitate the enforcement of fair lending laws in small business lending. The data, however, clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks that lack scale and compliance resources, and Section 1071 should either be repealed or community banks should be provided with a meaningful exception. Fraud losses are increasing at community banks and Reg CC needs to keep pace with the technology that banks and their customers are using, both now and particularly as the payments system transitions to real-time. All banks, credit unions, and others who utilize the payments system should be operating on the same level playing field when it comes to return reasons for fraud and acknowledging and communicating about fraud. The recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, OCC, Federal Reserve, CFPB) Legislation - Enhances Credit Opportunities in Rural America (ECORA) (H.R. 1872 and S.1641) (All Sections), interest earned on agricultural real estate and rural single family home loans would not be taxable (House and Senate, OCC, CFPB) Community Bank Access to Capital (S.1233) (All Sections), exempting banks under certain thresholds from Sarbanes-Oxley internal control attestations and FDIC annual reports, and revises the SECs definition of investor categories (House and Senate, OCC, CFPB) Corporate Transparency Act of 2019 (H.R. 2513) (All Sections), which amends the Bank Secrecy Act (BSA) to require beneficial ownership information to be collected by the Financial Crimes Enforcement Network (FinCEN) (House) Letters - Comment Letter to the Department of Housing and Urban Development (HUD) regarding HUDs implementation of the Fair Housing Acts Disparate Impact standard; Docket No FR-6111-P-02 and RIN 2529-AA98 (HUD) Comment Letter to the Federal Deposit Insurance Corporation (FDIC) regarding interest rate restrictions on institutions that are less than well capitalized (Deposit Rate Caps); RIN 3064-AF02 (FDIC) Comment Letter to the Federal Reserve regarding Notice and Request for Comments - Federal Reserve actions to support interbank settlement of faster payments [FedNow Service] (Federal Reserve) Comment Letter to the National Credit Union Administration (NCUA) regarding proposed rule about serving core-based/urban statistical areas (NCUA) Action Alerts - Action Alert regarding proposal to increase the Home Mortgage Disclosure Act (HMDA) thresholds for collecting and reporting data (CFPB) Action Alert regarding the Corporate Transparency Act of 2019 (H.R. 2513) (all Sections), which amends the Bank Secrecy Act (BSA) to require beneficial ownership information to be collected by the Financial Crimes Enforcement Network (FinCEN) (House) Action Alert regarding the Federal Reserves implementation of its FedNow (faster payments) Service (Federal Reserve) Action Alert regarding the National Credit Union Administration (NCUA) proposed rule about serving core-based/urban statistical areas (NCUA) Miscellaneous - Tax-exempt credit unions purchasing taxpaying community banks (House and Senate, OCC, CFPB) FDIC Listening Session on Supervisory Appeals and Dispute Resolution Process (FDIC) Closing the supervisory loophole for Industrial Loan Corporations (ILCs) (House)

CBAI Federal Policy Priorities - 2019 The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. The Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country. The swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018. The passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. Credit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders. The United States payments system (System), which is the very foundation of our financial services and economy, must be modernized to meet the demands of consumers and to keep pace with the rest of the world. System improvements must not be dominated by the largest banks and financial firms or private-sector non-banks. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system which requires the Federal Reserve to continue to play a preeminent role in the Systems improvement. The Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks). The reform of the housing GSEs remains critically important to the future of the housing market and the U.S. economy. American homeowners have benefited from the critical role Fannie Mae and Freddie Mac have played in helping finance homeownership for many decades. The GSEs have provided a steady, reliable source of funding for home mortgage lending through all economic cycles and in all markets. Community banks depend on the GSEs for direct access to the secondary market without having to sell their loans through larger financial institutions that compete with them. The GSEs allow community banks to retain the servicing of the loans they sell, which helps to keep delinquencies and foreclosures low. And, unlike other private investors or aggregators, the GSEs have a mandate to serve all markets at all times which is critical to maintaining liquidity when the markets are experiencing financial stress. Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable and reliable sources of funding for their members . However, given their unique relationship with thousands of community lenders, it may be appropriate for the FHLBs to support their members secondary market activities as aggregators or guarantors for residential mortgage loans, provided their current ability to serve their members is not impeded or threatened. Additionally, the FHFA should not impose an ongoing housing mission asset test on FHLB membership, which would undermine the reliability of FHLB funding. A vibrant agricultural and rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from further cuts or adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Community banks are strong guardians of the security and confidentiality of their customers information and are on the frontline of defending against cyber security threats. Core data security principals in legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants in the payment system should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; a national data security breach and notification standard should replace the current patchwork of state laws; and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations, only to achieve the same superior results they currently attain. While community banks represent less than 20% of banking industry assets, they make 60% of the small business loans and 80% of agricultural loans. The requirement for reporting small business data collection stems from Section 1071 of the Dodd-Frank Act and is meant to facilitate the enforcement of fair lending laws in small business lending. The data, however, clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks that lack scale and compliance resources, and Section 1071 should either be repealed or community banks should be provided with a meaningful exception. The recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, OCC, CFPB) Legislation - Enhances Credit Opportunities in Rural America (ECORA) (H.R. 1872 and S.1641) (All Sections), interest earned on agricultural real estate and rural single family home loans would not be taxable (House and Senate, OCC, CFPB) Letters - Comment Letter to the National Credit Union Administration (NCUA) regarding proposed rule about serving core-based/urban statistical areas (NCUA) Action Alerts - Action Alert regarding the National Credit Union Administration (NCUA) proposed rule about serving core-based/urban statistical areas (NCUA) Miscellaneous - Tax-exempt credit unions purchasing taxpaying community banks (House and Senate, OCC, CFPB)

CBAI Federal Policy Priorities - 2019 The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. The Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country. The swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018. The passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. Credit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders. The Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks). The recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, OCC, CFPB) Legislation - Enhances Credit Opportunities in Rural America (ECORA) (H.R. 1872 and S.1641) (All Sections), interest earned on agricultural real estate and rural single family home loans would not be taxable (House and Senate, OCC, CFPB) Letters - Comment Letter to the National Credit Union Administration (NCUA) regarding proposed rule about serving core-based/urban statistical areas (NCUA) Action Alerts - Action Alert regarding the National Credit Union Administration (NCUA) proposed rule about serving core-based/urban statistical areas (NCUA) Miscellaneous - Tax-exempt credit unions purchasing taxpaying community banks (House and Senate, OCC, CFPB)

CBAI Federal Policy Priorities - 2019 The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. The Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country. The swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018. The passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. Credit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders. The United States payments system (System), which is the very foundation of our financial services and economy, must be modernized to meet the demands of consumers and to keep pace with the rest of the world. System improvements must not be dominated by the largest banks and financial firms or private-sector non-banks. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system which requires the Federal Reserve to continue to play a preeminent role in the Systems improvement. The Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks). The Federal Deposit Insurance Corporation (FDIC) Deposit Rate Caps (Rate Caps) impact community banks ability to grow and thrive. The flaws in how the Rate Caps are calculated include: not reflecting competitive funding or investment opportunities; the largest banks extensive branch networks and their too-big-to-fail subsidies have an outsized influence on the Rate Caps; promotional and negotiated rates are excluded which present an incomplete picture of the deposit-rate landscape; and credit unions are omitted which wrongly ignores thousands of financial institutions that are similar to community banks. Also, during safety and soundness examinations for well capitalized banks, FDIC examiners are using the flawed Rate Caps as a benchmark in the analysis of bank liquidity, which inevitably results in faulty conclusions that can impact liquidity in a banks CAMELS rating. Without taking a position on the legalization of cannabis, it is a matter of public safety to have a safe harbor from federal sanctions for financial institutions that choose to serve legally-compliant cannabis-related business in states where cannabis is legal. Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant banking profession in the face of industry consolidation. The Federal Deposit Insurance Corporation (FDIC) has indicated a change in direction to finally get back on the right course. These encouraging signs must be closely monitored to assure that many new banks are chartered each year to help maintain the vitality of the community banking profession. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, which has served our nation well for over 150 years, where chartering and supervision is divided between the federal government and the states. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances on the immense power of the regulators, as well as improved rulemaking - as the benefit of each agencies expertise and experience is brought to bear on complex and controversial issues. The reform of the housing GSEs remains critically important to the future of the housing market and the U.S. economy. American homeowners have benefited from the critical role Fannie Mae and Freddie Mac have played in helping finance homeownership for many decades. The GSEs have provided a steady, reliable source of funding for home mortgage lending through all economic cycles and in all markets. Community banks depend on the GSEs for direct access to the secondary market without having to sell their loans through larger financial institutions that compete with them. The GSEs allow community banks to retain the servicing of the loans they sell, which helps to keep delinquencies and foreclosures low. And, unlike other private investors or aggregators, the GSEs have a mandate to serve all markets at all times which is critical to maintaining liquidity when the markets are experiencing financial stress. Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable and reliable sources of funding for their members . However, given their unique relationship with thousands of community lenders, it may be appropriate for the FHLBs to support their members secondary market activities as aggregators or guarantors for residential mortgage loans, provided their current ability to serve their members is not impeded or threatened. Additionally, the FHFA should not impose an ongoing housing mission asset test on FHLB membership, which would undermine the reliability of FHLB funding. A vibrant agricultural and rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from further cuts or adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Community banks are strong guardians of the security and confidentiality of their customers information and are on the frontline of defending against cyber security threats. Core data security principals in legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants in the payment system should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; a national data security breach and notification standard should replace the current patchwork of state laws; and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations, only to achieve the same superior results they currently attain. Regulations promulgated by the Consumer Financial Protection Bureau CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. The CFPB should not be unduly influencing marketplace behavior by targeting financial institutions, products, services, and practices which it deems to be undesirable or inappropriate regardless of what consumers want. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB, in the Dodd-Frank Act (Section 1022(b)(3)(A), has the statutory authority to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Office of Comptroller of the Currency (OCC) intends to issue special purpose national banking charters to Fintech companies. The OCCs intentions, however, raise many concerns. The very legal authority permitting the OCC to charter Fintechs has been challenged by the Conference of State Bank Supervisors (CSBS) as being fatally flawed. A single regulator acting unilaterally in the chartering, examining, supervising and regulating Fintechs is not in the best interests of the profession, consumers and the economy. Congress must provide the explicit statutory authority to charter Fintechs. If the OCC moves forward, it must guarantee that Fintechs will comply with all banking laws, rules and regulations, and that they be held to the same rigorous safety and soundness standards (e.g., supervision and regulation) that are currently being required of community banks and bank holding companies. Fintechs cannot have the advantages of a national bank charter with limited requirements, regulations and liability. The Financial Accounting Standards Board (FASB) has approved significant revisions to the way community banks reserve for their loan losses (i.e., the Current Expected Credit Loss (CECL) Model). After significant community banker input, FASB agreed to address community banker concerns and revised their Model proposal. The revised CECL is more flexible and scalable for community banks by allowing them to evaluate and adjust loan loss amounts using qualitative factors, historic losses, and their current operating systems such as spreadsheets, narratives and other noncomplex estimation methods. Community bankers and Congress must continue to be vigilant to assure the Model implementation provides a clear, practical and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. There is an emerging threat to the security of consumer data from the proliferation of companies seeking to access bank customer account information (i.e., customer data sharing). The Consumer Financial Protection Bureau (CFPB) is responsible under the Dodd-Frank Act to promulgate this rule. While community banks support responsible innovation in financial products and services, the integrity of consumer data and privacy is only as strong as the weakest link. Community banks are financially sound and take great care in protecting consumer privacy, but non-bank entities are typically not well capitalized, have no significant assets and are financially unable to make restitution in the event of a loss. They must none-the-less be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. The Consumer Financial Protection Bureaus (CFPB) small-dollar lending rule was intended to address its concerns about consumer abuse caused by payday and vehicle title lenders. The proposed rule was too broadly drafted and would have ensnared sensible community bank small-dollar consumer lending. Some exemptions were granted for community banks after a burdensome rulemaking process. Subsequently, the new CFPB Director proposed eliminating the underwriting provision, and the delay in the payment provision was continued by a U.S. District Judge. A carefully monitoring and appropriate action will be required, as the implementation of the rule unfolds, to minimize any negative impact on community banks small-dollar consumer lending. While community banks represent less than 20% of banking industry assets, they make 60% of the small business loans and 80% of agricultural loans. The requirement for reporting small business data collection stems from Section 1071 of the Dodd-Frank Act and is meant to facilitate the enforcement of fair lending laws in small business lending. The data, however, clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks that lack scale and compliance resources, and Section 1071 should either be repealed or community banks should be provided with a meaningful exception. Fraud losses are increasing at community banks and Reg CC needs to keep pace with the technology that banks and their customers are using, both now and particularly as the payments system transitions to real-time. All banks, credit unions, and others who utilize the payments system should be operating on the same level playing field when it comes to return reasons for fraud and acknowledging and communicating about fraud. The recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, FDIC, CFPB, Federal Reserve) Legislation - Enhances Credit Opportunities in Rural America (ECORA) (H.R. 1872 and S.1641) (All Sections), interest earned on agricultural real estate and rural single family home loans would not be taxable (House and Senate) Payments Modernization Act of 2019 (S.2243) (All Sections), regarding the Federal Reserve Systems role in faster (real-time) payments (Senate) Safe and Fair Enforcement Banking Act of 2019 (SAFE Act) (H.R. 1595) (All Sections), safe harbor for banking cannabis related businesses (House) Letters - Comment Letter to the IRS regarding Internal Revenue Code section 481(d), added to section 13543 of the Tax Cuts and Jobs Act (TCJA), Pub. L. No. 115-97 dealing with the treatment of section 481(a) adjustments that result when an S corporation terminates its S election and converts to a C corporation during the two year period beginning on the date of enactment of the TCJA, and where the change in status requires the taxpayer to change from the cash method of accounting to the accrual method. (IRS) Action Alerts - Action Alerts (two) regarding tax-exempt credit unions purchasing taxpaying community banks (House and Senate) Miscellaneous - Tax-exempt credit unions purchasing taxpaying community banks (House and Senate, Federal Reserve, CFPB, FDIC,) The Federal Reserve Systems role in faster payments (real-time payments). (House and Senate, FDIC, CFPB, Federal Reserve) Michelle Bowmans nomination to the Federal Reserve Board (Senate)

CBAI Federal Policy Priorities - 2019 The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. The Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country. The swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018. The passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. Credit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders. The United States payments system (System), which is the very foundation of our financial services and economy, must be modernized to meet the demands of consumers and to keep pace with the rest of the world. System improvements must not be dominated by the largest banks and financial firms or private-sector non-banks. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system which requires the Federal Reserve to continue to play a preeminent role in the Systems improvement. The Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks). The recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, FDIC, CFPB, Federal Reserve) Legislation - Enhances Credit Opportunities in Rural America (ECORA) (H.R. 1872 and S.1641) (All Sections), interest earned on agricultural real estate and rural single family home loans would not be taxable (House and Senate) Action Alerts - Action Alerts (two) regarding tax-exempt credit unions purchasing taxpaying community banks (House and Senate) Miscellaneous - Tax-exempt credit unions purchasing taxpaying community banks (House and Senate, Federal Reserve, CFPB, FDIC)

CBAI Federal Policy Priorities - 2019 The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. The Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country. The swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018. The passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. Credit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders. The Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks). The recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, FDIC, CFPB, Federal Reserve) Legislation - Enhances Credit Opportunities in Rural America (ECORA) (H.R. 1872 and S.1641) (All Sections), interest earned on agricultural real estate and rural single family home loans would not be taxable (House and Senate) Letters - Comment Letter to the IRS regarding Internal Revenue Code section 481(d), added to section 13543 of the Tax Cuts and Jobs Act (TCJA), Pub. L. No. 115-97 dealing with the treatment of section 481(a) adjustments that result when an S corporation terminates its S election and converts to a C corporation during the two year period beginning on the date of enactment of the TCJA, and where the change in status requires the taxpayer to change from the cash method of accounting to the accrual method (IRS) Action Alerts - Action Alerts (two) regarding tax-exempt credit unions purchasing taxpaying community banks (House and Senate) Miscellaneous - Tax-exempt credit unions purchasing taxpaying community banks (House and Senate, Federal Reserve, CFPB, FDIC)

CBAI Federal Policy Priorities - 2019 The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. The Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country. The swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018. The passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. Credit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders. The United States payments system (System), which is the very foundation of our financial services and economy, must be modernized to meet the demands of consumers and to keep pace with the rest of the world. System improvements must not be dominated by the largest banks and financial firms or private-sector non-banks. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system which requires the Federal Reserve to continue to play a preeminent role in the Systems improvement. The Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks). The Federal Deposit Insurance Corporation (FDIC) Deposit Rate Caps (Rate Caps) impact community banks ability to grow and thrive. The flaws in how the Rate Caps are calculated include: not reflecting competitive funding or investment opportunities; the largest banks extensive branch networks and their too-big-to-fail subsidies have an outsized influence on the Rate Caps; promotional and negotiated rates are excluded which present an incomplete picture of the deposit-rate landscape; and credit unions are omitted which wrongly ignores thousands of financial institutions that are similar to community banks. Also, during safety and soundness examinations for well capitalized banks, FDIC examiners are using the flawed Rate Caps as a benchmark in the analysis of bank liquidity, which inevitably results in faulty conclusions that can impact liquidity in a banks CAMELS rating. Without taking a position on the legalization of cannabis, it is a matter of public safety to have a safe harbor from federal sanctions for financial institutions that choose to serve legally-compliant cannabis-related business in states where cannabis is legal. Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant banking profession in the face of industry consolidation. The Federal Deposit Insurance Corporation (FDIC) has indicated a change in direction to finally get back on the right course. These encouraging signs must be closely monitored to assure that many new banks are chartered each year to help maintain the vitality of the community banking profession. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, which has served our nation well for over 150 years, where chartering and supervision is divided between the federal government and the states. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances on the immense power of the regulators, as well as improved rulemaking - as the benefit of each agencies expertise and experience is brought to bear on complex and controversial issues. The reform of the housing GSEs remains critically important to the future of the housing market and the U.S. economy. American homeowners have benefited from the critical role Fannie Mae and Freddie Mac have played in helping finance homeownership for many decades. The GSEs have provided a steady, reliable source of funding for home mortgage lending through all economic cycles and in all markets. Community banks depend on the GSEs for direct access to the secondary market without having to sell their loans through larger financial institutions that compete with them. The GSEs allow community banks to retain the servicing of the loans they sell, which helps to keep delinquencies and foreclosures low. And, unlike other private investors or aggregators, the GSEs have a mandate to serve all markets at all times which is critical to maintaining liquidity when the markets are experiencing financial stress. Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable and reliable sources of funding for their members . However, given their unique relationship with thousands of community lenders, it may be appropriate for the FHLBs to support their members secondary market activities as aggregators or guarantors for residential mortgage loans, provided their current ability to serve their members is not impeded or threatened. Additionally, the FHFA should not impose an ongoing housing mission asset test on FHLB membership, which would undermine the reliability of FHLB funding. A vibrant agricultural and rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from further cuts or adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Community banks are strong guardians of the security and confidentiality of their customers information and are on the frontline of defending against cyber security threats. Core data security principals in legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants in the payment system should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; a national data security breach and notification standard should replace the current patchwork of state laws; and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations, only to achieve the same superior results they currently attain. Regulations promulgated by the Consumer Financial Protection Bureau CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. The CFPB should not be unduly influencing marketplace behavior by targeting financial institutions, products, services, and practices which it deems to be undesirable or inappropriate regardless of what consumers want. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB, in the Dodd-Frank Act (Section 1022(b)(3)(A), has the statutory authority to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Office of Comptroller of the Currency (OCC) intends to issue special purpose national banking charters to Fintech companies. The OCCs intentions, however, raise many concerns. The very legal authority permitting the OCC to charter Fintechs has been challenged by the Conference of State Bank Supervisors (CSBS) as being fatally flawed. A single regulator acting unilaterally in the chartering, examining, supervising and regulating Fintechs is not in the best interests of the profession, consumers and the economy. Congress must provide the explicit statutory authority to charter Fintechs. If the OCC moves forward, it must guarantee that Fintechs will comply with all banking laws, rules and regulations, and that they be held to the same rigorous safety and soundness standards (e.g., supervision and regulation) that are currently being required of community banks and bank holding companies. Fintechs cannot have the advantages of a national bank charter with limited requirements, regulations and liability. The Financial Accounting Standards Board (FASB) has approved significant revisions to the way community banks reserve for their loan losses (i.e., the Current Expected Credit Loss (CECL) Model). After significant community banker input, FASB agreed to address community banker concerns and revised their Model proposal. The revised CECL is more flexible and scalable for community banks by allowing them to evaluate and adjust loan loss amounts using qualitative factors, historic losses, and their current operating systems such as spreadsheets, narratives and other noncomplex estimation methods. Community bankers and Congress must continue to be vigilant to assure the Model implementation provides a clear, practical and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. There is an emerging threat to the security of consumer data from the proliferation of companies seeking to access bank customer account information (i.e., customer data sharing). The Consumer Financial Protection Bureau (CFPB) is responsible under the Dodd-Frank Act to promulgate this rule. While community banks support responsible innovation in financial products and services, the integrity of consumer data and privacy is only as strong as the weakest link. Community banks are financially sound and take great care in protecting consumer privacy, but non-bank entities are typically not well capitalized, have no significant assets and are financially unable to make restitution in the event of a loss. They must none-the-less be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. The Consumer Financial Protection Bureaus (CFPB) small-dollar lending rule was intended to address its concerns about consumer abuse caused by payday and vehicle title lenders. The proposed rule was too broadly drafted and would have ensnared sensible community bank small-dollar consumer lending. Some exemptions were granted for community banks after a burdensome rulemaking process. Subsequently, the new CFPB Director proposed eliminating the underwriting provision, and the delay in the payment provision was continued by a U.S. District Judge. A carefully monitoring and appropriate action will be required, as the implementation of the rule unfolds, to minimize any negative impact on community banks small-dollar consumer lending. While community banks represent less than 20% of banking industry assets, they make 60% of the small business loans and 80% of agricultural loans. The requirement for reporting small business data collection stems from Section 1071 of the Dodd-Frank Act and is meant to facilitate the enforcement of fair lending laws in small business lending. The data, however, clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks that lack scale and compliance resources, and Section 1071 should either be repealed or community banks should be provided with a meaningful exception. Fraud losses are increasing at community banks and Reg CC needs to keep pace with the technology that banks and their customers are using, both now and particularly as the payments system transitions to real-time. All banks, credit unions, and others who utilize the payments system should be operating on the same level playing field when it comes to return reasons for fraud and acknowledging and communicating about fraud. The recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, FDIC, CFPB, Federal Reserve) Legislation - Enhances Credit Opportunities in Rural America (ECORA) (H.R. 1872 and S.1641) (All Sections), interest earned on agricultural real estate and rural single family home loans would not be taxable (House and Senate) Payments Modernization Act of 2019 (S.2243) (All Sections), regarding the Federal Reserve Systems role in faster (real-time) payments (Senate) Safe and Fair Enforcement Banking Act of 2019 (SAFE Act) (H.R. 1595) (All Sections), safe harbor for banking cannabis related businesses (House) Letters - Comment Letter to the IRS regarding Internal Revenue Code section 481(d), added to section 13543 of the Tax Cuts and Jobs Act (TCJA), Pub. L. No. 115-97 dealing with the treatment of section 481(a) adjustments that result when an S corporation terminates its S election and converts to a C corporation during the two year period beginning on the date of enactment of the TCJA, and where the change in status requires the taxpayer to change from the cash method of accounting to the accrual method. (IRS) Action Alerts - Action Alerts (two) regarding tax-exempt credit unions purchasing taxpaying community banks (House and Senate) Miscellaneous - Tax-exempt credit unions purchasing taxpaying community banks (House and Senate, Federal Reserve, CFPB, FDIC,) The Federal Reserve Systems role in faster payments (real-time payments). (House and Senate, FDIC, CFPB, Federal Reserve) Michelle Bowmans nomination to the Federal Reserve Board (Senate)

CBAI Federal Policy Priorities - 2019 The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. The Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country. The swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018. The passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. Credit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders. The United States payments system (System), which is the very foundation of our financial services and economy, must be modernized to meet the demands of consumers and to keep pace with the rest of the world. System improvements must not be dominated by the largest banks and financial firms or private-sector non-banks. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system which requires the Federal Reserve to continue to play a preeminent role in the Systems improvement. The Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks). The reform of the housing GSEs remains critically important to the future of the housing market and the U.S. economy. American homeowners have benefited from the critical role Fannie Mae and Freddie Mac have played in helping finance homeownership for many decades. The GSEs have provided a steady, reliable source of funding for home mortgage lending through all economic cycles and in all markets. Community banks depend on the GSEs for direct access to the secondary market without having to sell their loans through larger financial institutions that compete with them. The GSEs allow community banks to retain the servicing of the loans they sell, which helps to keep delinquencies and foreclosures low. And, unlike other private investors or aggregators, the GSEs have a mandate to serve all markets at all times which is critical to maintaining liquidity when the markets are experiencing financial stress. Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable and reliable sources of funding for their members . However, given their unique relationship with thousands of community lenders, it may be appropriate for the FHLBs to support their members secondary market activities as aggregators or guarantors for residential mortgage loans, provided their current ability to serve their members is not impeded or threatened. Additionally, the FHFA should not impose an ongoing housing mission asset test on FHLB membership, which would undermine the reliability of FHLB funding. Community banks are strong guardians of the security and confidentiality of their customers information and are on the frontline of defending against cyber security threats. Core data security principals in legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants in the payment system should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; a national data security breach and notification standard should replace the current patchwork of state laws; and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations, only to achieve the same superior results they currently attain. Regulations promulgated by the Consumer Financial Protection Bureau CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. The CFPB should not be unduly influencing marketplace behavior by targeting financial institutions, products, services, and practices which it deems to be undesirable or inappropriate regardless of what consumers want. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB, in the Dodd-Frank Act (Section 1022(b)(3)(A), has the statutory authority to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. There is an emerging threat to the security of consumer data from the proliferation of companies seeking to access bank customer account information (i.e., customer data sharing). The Consumer Financial Protection Bureau (CFPB) is responsible under the Dodd-Frank Act to promulgate this rule. While community banks support responsible innovation in financial products and services, the integrity of consumer data and privacy is only as strong as the weakest link. Community banks are financially sound and take great care in protecting consumer privacy, but non-bank entities are typically not well capitalized, have no significant assets and are financially unable to make restitution in the event of a loss. They must none-the-less be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. The Consumer Financial Protection Bureaus (CFPB) small-dollar lending rule was intended to address its concerns about consumer abuse caused by payday and vehicle title lenders. The proposed rule was too broadly drafted and would have ensnared sensible community bank small-dollar consumer lending. Some exemptions were granted for community banks after a burdensome rulemaking process. Subsequently, the new CFPB Director proposed eliminating the underwriting provision, and the delay in the payment provision was continued by a U.S. District Judge. A carefully monitoring and appropriate action will be required, as the implementation of the rule unfolds, to minimize any negative impact on community banks small-dollar consumer lending. The recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, FDIC, CFPB, Federal Reserve) Legislation - Enhances Credit Opportunities in Rural America (ECORA) (H.R. 1872 and S.1641) (All Sections), interest earned on agricultural real estate and rural single family home loans would not be taxable (House and Senate) Action Alerts - Action Alerts (two) regarding tax-exempt credit unions purchasing taxpaying community banks (House and Senate) Miscellaneous - Tax-exempt credit unions purchasing taxpaying community banks (House and Senate, Federal Reserve, CFPB, FDIC)

CBAI Federal Policy Priorities - 2019 The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. The Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country. The swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018. The passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. Credit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders. The United States payments system (System), which is the very foundation of our financial services and economy, must be modernized to meet the demands of consumers and to keep pace with the rest of the world. System improvements must not be dominated by the largest banks and financial firms or private-sector non-banks. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system which requires the Federal Reserve to continue to play a preeminent role in the Systems improvement. The Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks). Community banks are strong guardians of the security and confidentiality of their customers information and are on the frontline of defending against cyber security threats. Core data security principals in legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants in the payment system should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; a national data security breach and notification standard should replace the current patchwork of state laws; and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations, only to achieve the same superior results they currently attain. There is an emerging threat to the security of consumer data from the proliferation of companies seeking to access bank customer account information (i.e., customer data sharing). The Consumer Financial Protection Bureau (CFPB) is responsible under the Dodd-Frank Act to promulgate this rule. While community banks support responsible innovation in financial products and services, the integrity of consumer data and privacy is only as strong as the weakest link. Community banks are financially sound and take great care in protecting consumer privacy, but non-bank entities are typically not well capitalized, have no significant assets and are financially unable to make restitution in the event of a loss. They must none-the-less be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. While community banks represent less than 20% of banking industry assets, they make 60% of the small business loans and 80% of agricultural loans. The requirement for reporting small business data collection stems from Section 1071 of the Dodd-Frank Act and is meant to facilitate the enforcement of fair lending laws in small business lending. The data, however, clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks that lack scale and compliance resources, and Section 1071 should either be repealed or community banks should be provided with a meaningful exception. The recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, FDIC, CFPB, Federal Reserve) Legislation - Enhances Credit Opportunities in Rural America (ECORA) (H.R. 1872 and S.1641) (All Sections), interest earned on agricultural real estate and rural single family home loans would not be taxable (House and Senate) Safe and Fair Enforcement Banking Act of 2019 (SAFE Act) (H.R. 1595) (All Sections), safe harbor for banking cannabis related businesses (House) Action Alerts - Action Alerts (two) regarding tax-exempt credit unions purchasing taxpaying community banks (House and Senate) Miscellaneous - Tax-exempt credit unions purchasing taxpaying community banks (House and Senate, Federal Reserve, CFPB, FDIC)

Federal Policy Priorities - 2019 The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. The Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country. The swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018. The passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. Credit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders. The United States payments system (System), which is the very foundation of our financial services and economy, must be modernized to meet the demands of consumers and to keep pace with the rest of the world. System improvements must not be dominated by the largest banks and financial firms or private-sector non-banks. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system which requires the Federal Reserve to continue to play a preeminent role in the Systems improvement. The Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks). The recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, FDIC) Legislation - Potential legislation to increase private investment limits on banks investing in SBICs from 5% of total capital and surplus to 15% of total capital and surplus (Senate) Action Alerts - Action Alert regarding tax-exempt credit unions purchasing taxpaying community banks (House and Senate)

Federal Policy Priorities - 2019 The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. The Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country. The swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018. The passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. Credit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders. The United States payments system (System), which is the very foundation of our financial services and economy, must be modernized to meet the demands of consumers and to keep pace with the rest of the world. System improvements must not be dominated by the largest banks and financial firms or private-sector non-banks. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system which requires the Federal Reserve to continue to play a preeminent role in the Systems improvement. The Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks). The reform of the housing GSEs remains critically important to the future of the housing market and the U.S. economy. American homeowners have benefited from the critical role Fannie Mae and Freddie Mac have played in helping finance homeownership for many decades. The GSEs have provided a steady, reliable source of funding for home mortgage lending through all economic cycles and in all markets. Community banks depend on the GSEs for direct access to the secondary market without having to sell their loans through larger financial institutions that compete with them. The GSEs allow community banks to retain the servicing of the loans they sell, which helps to keep delinquencies and foreclosures low. And, unlike other private investors or aggregators, the GSEs have a mandate to serve all markets at all times which is critical to maintaining liquidity when the markets are experiencing financial stress. Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable and reliable sources of funding for their members . However, given their unique relationship with thousands of community lenders, it may be appropriate for the FHLBs to support their members secondary market activities as aggregators or guarantors for residential mortgage loans, provided their current ability to serve their members is not impeded or threatened. Additionally, the FHFA should not impose an ongoing housing mission asset test on FHLB membership, which would undermine the reliability of FHLB funding. A vibrant agricultural and rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from further cuts or adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Community banks are strong guardians of the security and confidentiality of their customers information and are on the frontline of defending against cyber security threats. Core data security principals in legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants in the payment system should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; a national data security breach and notification standard should replace the current patchwork of state laws; and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations, only to achieve the same superior results they currently attain. While community banks represent less than 20% of banking industry assets, they make 60% of the small business loans and 80% of agricultural loans. The requirement for reporting small business data collection stems from Section 1071 of the Dodd-Frank Act and is meant to facilitate the enforcement of fair lending laws in small business lending. The data, however, clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks that lack scale and compliance resources, and Section 1071 should either be repealed or community banks should be provided with a meaningful exception. The recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, FDIC) Action Alerts - Action Alert regarding raising coverage thresholds for collecting and reporting data about closed-end mortgages under the Home Mortgage Disclosure Act (HMDA) to 100 loans and making permanent the 500 open-end lines of credit threshold instead of reverting back to 200 in 2022 (CFPB) Action Alert regarding tax-exempt credit unions purchasing taxpaying community banks (House and Senate)

Federal Policy Priorities - 2019 The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. The Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country. The swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018. The passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. Credit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders. The United States payments system (System), which is the very foundation of our financial services and economy, must be modernized to meet the demands of consumers and to keep pace with the rest of the world. System improvements must not be dominated by the largest banks and financial firms or private-sector non-banks. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system which requires the Federal Reserve to continue to play a preeminent role in the Systems improvement. The Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks). The Federal Deposit Insurance Corporation (FDIC) Deposit Rate Caps (Rate Caps) impact community banks ability to grow and thrive. The flaws in how the Rate Caps are calculated include: not reflecting competitive funding or investment opportunities; the largest banks extensive branch networks and their too-big-to-fail subsidies have an outsized influence on the Rate Caps; promotional and negotiated rates are excluded which present an incomplete picture of the deposit-rate landscape; and credit unions are omitted which wrongly ignores thousands of financial institutions that are similar to community banks. Also, during safety and soundness examinations for well capitalized banks, FDIC examiners are using the flawed Rate Caps as a benchmark in the analysis of bank liquidity, which inevitably results in faulty conclusions that can impact liquidity in a banks CAMELS rating. Without taking a position on the legalization of cannabis, it is a matter of public safety to have a safe harbor from federal sanctions for financial institutions that choose to serve legally-compliant cannabis-related business in states where cannabis is legal. Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant banking profession in the face of industry consolidation. The Federal Deposit Insurance Corporation (FDIC) has indicated a change in direction to finally get back on the right course. These encouraging signs must be closely monitored to assure that many new banks are chartered each year to help maintain the vitality of the community banking profession. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, which has served our nation well for over 150 years, where chartering and supervision is divided between the federal government and the states. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances on the immense power of the regulators, as well as improved rulemaking - as the benefit of each agencies expertise and experience is brought to bear on complex and controversial issues. The reform of the housing GSEs remains critically important to the future of the housing market and the U.S. economy. American homeowners have benefited from the critical role Fannie Mae and Freddie Mac have played in helping finance homeownership for many decades. The GSEs have provided a steady, reliable source of funding for home mortgage lending through all economic cycles and in all markets. Community banks depend on the GSEs for direct access to the secondary market without having to sell their loans through larger financial institutions that compete with them. The GSEs allow community banks to retain the servicing of the loans they sell, which helps to keep delinquencies and foreclosures low. And, unlike other private investors or aggregators, the GSEs have a mandate to serve all markets at all times which is critical to maintaining liquidity when the markets are experiencing financial stress. Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable and reliable sources of funding for their members . However, given their unique relationship with thousands of community lenders, it may be appropriate for the FHLBs to support their members secondary market activities as aggregators or guarantors for residential mortgage loans, provided their current ability to serve their members is not impeded or threatened. Additionally, the FHFA should not impose an ongoing housing mission asset test on FHLB membership, which would undermine the reliability of FHLB funding. A vibrant agricultural and rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from further cuts or adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Community banks are strong guardians of the security and confidentiality of their customers information and are on the frontline of defending against cyber security threats. Core data security principals in legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants in the payment system should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; a national data security breach and notification standard should replace the current patchwork of state laws; and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations, only to achieve the same superior results they currently attain. Regulations promulgated by the Consumer Financial Protection Bureau CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. The CFPB should not be unduly influencing marketplace behavior by targeting financial institutions, products, services, and practices which it deems to be undesirable or inappropriate regardless of what consumers want. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB, in the Dodd-Frank Act (Section 1022(b)(3)(A), has the statutory authority to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Office of Comptroller of the Currency (OCC) intends to issue special purpose national banking charters to Fintech companies. The OCCs intentions, however, raise many concerns. The very legal authority permitting the OCC to charter Fintechs has been challenged by the Conference of State Bank Supervisors (CSBS) as being fatally flawed. A single regulator acting unilaterally in the chartering, examining, supervising and regulating Fintechs is not in the best interests of the profession, consumers and the economy. Congress must provide the explicit statutory authority to charter Fintechs. If the OCC moves forward, it must guarantee that Fintechs will comply with all banking laws, rules and regulations, and that they be held to the same rigorous safety and soundness standards (e.g., supervision and regulation) that are currently being required of community banks and bank holding companies. Fintechs cannot have the advantages of a national bank charter with limited requirements, regulations and liability. The Financial Accounting Standards Board (FASB) has approved significant revisions to the way community banks reserve for their loan losses (i.e., the Current Expected Credit Loss (CECL) Model). After significant community banker input, FASB agreed to address community banker concerns and revised their Model proposal. The revised CECL is more flexible and scalable for community banks by allowing them to evaluate and adjust loan loss amounts using qualitative factors, historic losses, and their current operating systems such as spreadsheets, narratives and other noncomplex estimation methods. Community bankers and Congress must continue to be vigilant to assure the Model implementation provides a clear, practical and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. There is an emerging threat to the security of consumer data from the proliferation of companies seeking to access bank customer account information (i.e., customer data sharing). The Consumer Financial Protection Bureau (CFPB) is responsible under the Dodd-Frank Act to promulgate this rule. While community banks support responsible innovation in financial products and services, the integrity of consumer data and privacy is only as strong as the weakest link. Community banks are financially sound and take great care in protecting consumer privacy, but non-bank entities are typically not well capitalized, have no significant assets and are financially unable to make restitution in the event of a loss. They must none-the-less be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. The Consumer Financial Protection Bureaus (CFPB) small-dollar lending rule was intended to address its concerns about consumer abuse caused by payday and vehicle title lenders. The proposed rule was too broadly drafted and would have ensnared sensible community bank small-dollar consumer lending. Some exemptions were granted for community banks after a burdensome rulemaking process. Subsequently, the new CFPB Director proposed eliminating the underwriting provision, and the delay in the payment provision was continued by a U.S. District Judge. A carefully monitoring and appropriate action will be required, as the implementation of the rule unfolds, to minimize any negative impact on community banks small-dollar consumer lending. While community banks represent less than 20% of banking industry assets, they make 60% of the small business loans and 80% of agricultural loans. The requirement for reporting small business data collection stems from Section 1071 of the Dodd-Frank Act and is meant to facilitate the enforcement of fair lending laws in small business lending. The data, however, clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks that lack scale and compliance resources, and Section 1071 should either be repealed or community banks should be provided with a meaningful exception. Fraud losses are increasing at community banks and Reg CC needs to keep pace with the technology that banks and their customers are using, both now and particularly as the payments system transitions to real-time. All banks, credit unions, and others who utilize the payments system should be operating on the same level playing field when it comes to return reasons for fraud and acknowledging and communicating about fraud. The recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, FDIC) Legislation - Potential legislation to increase private investment limits on banks investing in SBICs from 5% of total capital and surplus to 15% of total capital and surplus (Senate) Potential reintroduction in the 116th Congress, of the 115th Congress S. 378 (Access to Business Credit Act of 2018), to exclude from gross income certain banks interest received on small business loans of up to $5 million (Senate) Safe and Fair Enforcement Banking Act of 2019 (S. 1200) - provides a safe harbor for banks which provide financial services to legal cannabis-related business (Senate) Letters - Comment Letter to the OCC, Federal Reserve and the FDIC regarding the Regulatory Capital Rule: Capital Simplification for Qualifying Community Banking Organizations [Community Bank Leverage Ratio (CBLR)] - OCC Docket ID OCC-2018-0040, Federal Reserve Docket No. R-1638, FDIC RIN 3064-AE91 (OCC, Federal Reserve and the FDIC) Action Alerts - Action Alert regarding raising coverage thresholds for collecting and reporting data about closed-end mortgages under the Home Mortgage Disclosure Act (HMDA) to 100 loans and making permanent the 500 open-end lines of credit threshold instead of reverting back to 200 in 2022 (CFPB) Action Alert regarding tax-exempt credit unions purchasing taxpaying community banks (House and Senate)

Federal Policy Priorities - 2019 The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. The Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country. The swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018. The passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. Credit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders. The United States payments system (System), which is the very foundation of our financial services and economy, must be modernized to meet the demands of consumers and to keep pace with the rest of the world. System improvements must not be dominated by the largest banks and financial firms or private-sector non-banks. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system which requires the Federal Reserve to continue to play a preeminent role in the Systems improvement. The Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks). The reform of the housing GSEs remains critically important to the future of the housing market and the U.S. economy. American homeowners have benefited from the critical role Fannie Mae and Freddie Mac have played in helping finance homeownership for many decades. The GSEs have provided a steady, reliable source of funding for home mortgage lending through all economic cycles and in all markets. Community banks depend on the GSEs for direct access to the secondary market without having to sell their loans through larger financial institutions that compete with them. The GSEs allow community banks to retain the servicing of the loans they sell, which helps to keep delinquencies and foreclosures low. And, unlike other private investors or aggregators, the GSEs have a mandate to serve all markets at all times which is critical to maintaining liquidity when the markets are experiencing financial stress. Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable and reliable sources of funding for their members . However, given their unique relationship with thousands of community lenders, it may be appropriate for the FHLBs to support their members secondary market activities as aggregators or guarantors for residential mortgage loans, provided their current ability to serve their members is not impeded or threatened. Additionally, the FHFA should not impose an ongoing housing mission asset test on FHLB membership, which would undermine the reliability of FHLB funding. Community banks are strong guardians of the security and confidentiality of their customers information and are on the frontline of defending against cyber security threats. Core data security principals in legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants in the payment system should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; a national data security breach and notification standard should replace the current patchwork of state laws; and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations, only to achieve the same superior results they currently attain. Regulations promulgated by the Consumer Financial Protection Bureau CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. The CFPB should not be unduly influencing marketplace behavior by targeting financial institutions, products, services, and practices which it deems to be undesirable or inappropriate regardless of what consumers want. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB, in the Dodd-Frank Act (Section 1022(b)(3)(A), has the statutory authority to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. There is an emerging threat to the security of consumer data from the proliferation of companies seeking to access bank customer account information (i.e., customer data sharing). The Consumer Financial Protection Bureau (CFPB) is responsible under the Dodd-Frank Act to promulgate this rule. While community banks support responsible innovation in financial products and services, the integrity of consumer data and privacy is only as strong as the weakest link. Community banks are financially sound and take great care in protecting consumer privacy, but non-bank entities are typically not well capitalized, have no significant assets and are financially unable to make restitution in the event of a loss. They must none-the-less be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. The Consumer Financial Protection Bureaus (CFPB) small-dollar lending rule was intended to address its concerns about consumer abuse caused by payday and vehicle title lenders. The proposed rule was too broadly drafted and would have ensnared sensible community bank small-dollar consumer lending. Some exemptions were granted for community banks after a burdensome rulemaking process. Subsequently, the new CFPB Director proposed eliminating the underwriting provision, and the delay in the payment provision was continued by a U.S. District Judge. A carefully monitoring and appropriate action will be required, as the implementation of the rule unfolds, to minimize any negative impact on community banks small-dollar consumer lending. The recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, FDIC) Action Alerts - Action Alert regarding raising coverage thresholds for collecting and reporting data about closed-end mortgages under the Home Mortgage Disclosure Act (HMDA) to 100 loans and making permanent the 500 open-end lines of credit threshold instead of reverting back to 200 in 2022 (CFPB) Action Alert regarding tax-exempt credit unions purchasing taxpaying community banks (House and Senate)

Federal Policy Priorities - 2019 The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. The Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country. The swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018. The passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. Credit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders. The United States payments system (System), which is the very foundation of our financial services and economy, must be modernized to meet the demands of consumers and to keep pace with the rest of the world. System improvements must not be dominated by the largest banks and financial firms or private-sector non-banks. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system which requires the Federal Reserve to continue to play a preeminent role in the Systems improvement. The Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks). The Federal Deposit Insurance Corporation (FDIC) Deposit Rate Caps (Rate Caps) impact community banks ability to grow and thrive. The flaws in how the Rate Caps are calculated include: not reflecting competitive funding or investment opportunities; the largest banks extensive branch networks and their too-big-to-fail subsidies have an outsized influence on the Rate Caps; promotional and negotiated rates are excluded which present an incomplete picture of the deposit-rate landscape; and credit unions are omitted which wrongly ignores thousands of financial institutions that are similar to community banks. Also, during safety and soundness examinations for well capitalized banks, FDIC examiners are using the flawed Rate Caps as a benchmark in the analysis of bank liquidity, which inevitably results in faulty conclusions that can impact liquidity in a banks CAMELS rating. Without taking a position on the legalization of cannabis, it is a matter of public safety to have a safe harbor from federal sanctions for financial institutions that choose to serve legally-compliant cannabis-related business in states where cannabis is legal. Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant banking profession in the face of industry consolidation. The Federal Deposit Insurance Corporation (FDIC) has indicated a change in direction to finally get back on the right course. These encouraging signs must be closely monitored to assure that many new banks are chartered each year to help maintain the vitality of the community banking profession. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, which has served our nation well for over 150 years, where chartering and supervision is divided between the federal government and the states. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances on the immense power of the regulators, as well as improved rulemaking - as the benefit of each agencies expertise and experience is brought to bear on complex and controversial issues. The reform of the housing GSEs remains critically important to the future of the housing market and the U.S. economy. American homeowners have benefited from the critical role Fannie Mae and Freddie Mac have played in helping finance homeownership for many decades. The GSEs have provided a steady, reliable source of funding for home mortgage lending through all economic cycles and in all markets. Community banks depend on the GSEs for direct access to the secondary market without having to sell their loans through larger financial institutions that compete with them. The GSEs allow community banks to retain the servicing of the loans they sell, which helps to keep delinquencies and foreclosures low. And, unlike other private investors or aggregators, the GSEs have a mandate to serve all markets at all times which is critical to maintaining liquidity when the markets are experiencing financial stress. Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable and reliable sources of funding for their members . However, given their unique relationship with thousands of community lenders, it may be appropriate for the FHLBs to support their members secondary market activities as aggregators or guarantors for residential mortgage loans, provided their current ability to serve their members is not impeded or threatened. Additionally, the FHFA should not impose an ongoing housing mission asset test on FHLB membership, which would undermine the reliability of FHLB funding. A vibrant agricultural and rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from further cuts or adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Community banks are strong guardians of the security and confidentiality of their customers information and are on the frontline of defending against cyber security threats. Core data security principals in legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants in the payment system should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; a national data security breach and notification standard should replace the current patchwork of state laws; and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations, only to achieve the same superior results they currently attain. Regulations promulgated by the Consumer Financial Protection Bureau CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. The CFPB should not be unduly influencing marketplace behavior by targeting financial institutions, products, services, and practices which it deems to be undesirable or inappropriate regardless of what consumers want. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB, in the Dodd-Frank Act (Section 1022(b)(3)(A), has the statutory authority to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Office of Comptroller of the Currency (OCC) intends to issue special purpose national banking charters to Fintech companies. The OCCs intentions, however, raise many concerns. The very legal authority permitting the OCC to charter Fintechs has been challenged by the Conference of State Bank Supervisors (CSBS) as being fatally flawed. A single regulator acting unilaterally in the chartering, examining, supervising and regulating Fintechs is not in the best interests of the profession, consumers and the economy. Congress must provide the explicit statutory authority to charter Fintechs. If the OCC moves forward, it must guarantee that Fintechs will comply with all banking laws, rules and regulations, and that they be held to the same rigorous safety and soundness standards (e.g., supervision and regulation) that are currently being required of community banks and bank holding companies. Fintechs cannot have the advantages of a national bank charter with limited requirements, regulations and liability. The Financial Accounting Standards Board (FASB) has approved significant revisions to the way community banks reserve for their loan losses (i.e., the Current Expected Credit Loss (CECL) Model). After significant community banker input, FASB agreed to address community banker concerns and revised their Model proposal. The revised CECL is more flexible and scalable for community banks by allowing them to evaluate and adjust loan loss amounts using qualitative factors, historic losses, and their current operating systems such as spreadsheets, narratives and other noncomplex estimation methods. Community bankers and Congress must continue to be vigilant to assure the Model implementation provides a clear, practical and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. There is an emerging threat to the security of consumer data from the proliferation of companies seeking to access bank customer account information (i.e., customer data sharing). The Consumer Financial Protection Bureau (CFPB) is responsible under the Dodd-Frank Act to promulgate this rule. While community banks support responsible innovation in financial products and services, the integrity of consumer data and privacy is only as strong as the weakest link. Community banks are financially sound and take great care in protecting consumer privacy, but non-bank entities are typically not well capitalized, have no significant assets and are financially unable to make restitution in the event of a loss. They must none-the-less be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. The Consumer Financial Protection Bureaus (CFPB) small-dollar lending rule was intended to address its concerns about consumer abuse caused by payday and vehicle title lenders. The proposed rule was too broadly drafted and would have ensnared sensible community bank small-dollar consumer lending. Some exemptions were granted for community banks after a burdensome rulemaking process. Subsequently, the new CFPB Director proposed eliminating the underwriting provision, and the delay in the payment provision was continued by a U.S. District Judge. A carefully monitoring and appropriate action will be required, as the implementation of the rule unfolds, to minimize any negative impact on community banks small-dollar consumer lending. While community banks represent less than 20% of banking industry assets, they make 60% of the small business loans and 80% of agricultural loans. The requirement for reporting small business data collection stems from Section 1071 of the Dodd-Frank Act and is meant to facilitate the enforcement of fair lending laws in small business lending. The data, however, clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks that lack scale and compliance resources, and Section 1071 should either be repealed or community banks should be provided with a meaningful exception. Fraud losses are increasing at community banks and Reg CC needs to keep pace with the technology that banks and their customers are using, both now and particularly as the payments system transitions to real-time. All banks, credit unions, and others who utilize the payments system should be operating on the same level playing field when it comes to return reasons for fraud and acknowledging and communicating about fraud. The recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, FDIC) Legislation - Potential legislation to increase private investment limits on banks investing in SBICs from 5% of total capital and surplus to 15% of total capital and surplus (Senate) Potential reintroduction in the 116th Congress, of the 115th Congress S. 378 (Access to Business Credit Act of 2018), to exclude from gross income certain banks interest received on small business loans of up to $5 million (Senate) Safe and Fair Enforcement Banking Act of 2019 (S. 1200) - provides a safe harbor for banks which provide financial services to legal cannabis-related business (Senate) Letters - Comment Letter to the OCC, Federal Reserve and the FDIC regarding the Regulatory Capital Rule: Capital Simplification for Qualifying Community Banking Organizations [Community Bank Leverage Ratio (CBLR)] - OCC Docket ID OCC-2018-0040, Federal Reserve Docket No. R-1638, FDIC RIN 3064-AE91 (OCC, Federal Reserve and the FDIC) Action Alerts - Action Alert regarding raising coverage thresholds for collecting and reporting data about closed-end mortgages under the Home Mortgage Disclosure Act (HMDA) to 100 loans and making permanent the 500 open-end lines of credit threshold instead of reverting back to 200 in 2022 (CFPB) Action Alert regarding tax-exempt credit unions purchasing taxpaying community banks (House and Senate)

Federal Policy Priorities - 2019 The Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. The Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country. The swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018. The passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. Credit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders. The United States payments system (System), which is the very foundation of our financial services and economy, must be modernized to meet the demands of consumers and to keep pace with the rest of the world. System improvements must not be dominated by the largest banks and financial firms or private-sector non-banks. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system which requires the Federal Reserve to continue to play a preeminent role in the Systems improvement. The Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks). Community banks are strong guardians of the security and confidentiality of their customers information and are on the frontline of defending against cyber security threats. Core data security principals in legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants in the payment system should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; a national data security breach and notification standard should replace the current patchwork of state laws; and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations, only to achieve the same superior results they currently attain. There is an emerging threat to the security of consumer data from the proliferation of companies seeking to access bank customer account information (i.e., customer data sharing). The Consumer Financial Protection Bureau (CFPB) is responsible under the Dodd-Frank Act to promulgate this rule. While community banks support responsible innovation in financial products and services, the integrity of consumer data and privacy is only as strong as the weakest link. Community banks are financially sound and take great care in protecting consumer privacy, but non-bank entities are typically not well capitalized, have no significant assets and are financially unable to make restitution in the event of a loss. They must none-the-less be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. While community banks represent less than 20% of banking industry assets, they make 60% of the small business loans and 80% of agricultural loans. The requirement for reporting small business data collection stems from Section 1071 of the Dodd-Frank Act and is meant to facilitate the enforcement of fair lending laws in small business lending. The data, however, clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks that lack scale and compliance resources, and Section 1071 should either be repealed or community banks should be provided with a meaningful exception. The recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House, Senate, FDIC) Legislation - Potential legislation to increase private investment limits on banks investing in SBICs from 5% of total capital and surplus to 15% of total capital and surplus (Senate) Potential reintroduction in the 116th Congress, of the 115th Congress S. 378 (Access to Business Credit Act of 2018), to exclude from gross income certain banks interest received on small business loans of up to $5 million (Senate) Safe and Fair Enforcement Banking Act of 2019 (S. 1200) - provides a safe harbor for banks which provide financial services to legal cannabis-related business (Senate) Action Alerts - Action Alert regarding tax-exempt credit unions purchasing taxpaying community banks (House and Senate)

Legislation - H.R. 1595 the Secure and Fair Enforcement (SAFE) Banking Act regarding a safe harbor for financial institutions that chose to serve legally-compliant cannabis-related businesses (House) Letters - Comment Letter to the OCC, Federal Reserve and the FDIC regarding Reduced [Call Report] Reporting for Covered Repository Institutions - Docket ID OCC-2018-0032, Docket No. R-1618 and RIN 7100-AF12, and FDIC RIN-3064-AE82 (OCC, Federal Reserve, FDIC) Comment Letter to the FDIC regarding Request for Information on Small-Dollar Lending - RIN 3064-ZA04 (FDIC) Comment Letter to the FDIC regarding Request for Information on the FDICs Deposit Insurance Application Process - RIN 3064-ZA03 (FDIC) Action Alerts - Action Alert regarding the implementation of Section 205 of S. 2155 (115th Congress) requiring a short-form Call Report for 1st and 3rd quarters (OCC, Federal Reserve, FDIC) Action Alert regarding Section 201 of S. 2155 (115th Congress) concerning capital simplification and the Community Bank Leverage Ratio (CBLR) (OCC, Federal Reserve, FDIC) Miscellaneous - Implementation of S. 2155 (115th Congress) - The Economic Growth, Regulatory Relief and Consumer Protection Act - community bank regulatory relief - in particular Section 201 concerning capital simplification and the Community Bank Leverage Ratio (CBLR), and Section 205 concerning a short-form Call Report for 1st and 3rd quarters (CFPB, House and Senate) Bank Secrecy Act (BSA) modernization - Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs) thresholds (CFPB, House and Senate) Tax credit to offset the cost of BSA compliance (CFPB, House and Senate) Small Business Data Collection (Section 1071 of the Dodd-Frank Act) (CFPB, House and Senate) The Federal Reserves Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (CFPB, House and Senate) Modification of the FDICs Deposit Rate Caps (CFPB, House and Senate) Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions and fintechs in CRA compliance, examination and enforcement (CFPB, House and Senate) Principals of GSE Reform (CFPB, House and Senate) Agriculture and rural America / rural economic development (CFPB, House and Senate) Expansionist Agenda of Credit Unions (CFPB, House and Senate) Expansionist Agenda of the Farm Credit System (CFPB, House and Senate) De novo bank formation, specifically FDIC approval of applications for deposit insurance (House and Senate, FDIC) CFPB exemption authority under Section 1022 of the Dodd-Frank Act (CFPB) TRID and underwriting requirements under the ATR/QM (CFPB)

Miscellaneous - The Federal Reserves Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (CFPB, House and Senate) Bank Secrecy Act (BSA) modernization - Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs) thresholds (CFPB, House and Senate) Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions and fintechs in CRA compliance, examination and enforcement (CFPB, House and Senate) Principals of GSE Reform (CFPB, House and Senate) Agriculture and rural America / rural economic development (CFPB, House and Senate) Expansionist Agenda of Credit Unions (CFPB, House and Senate) Expansionist Agenda of the Farm Credit System (CFPB, House and Senate) TRID and underwriting requirements under the ATR/QM (CFPB)

Letters - Comment Letter to the FDIC regarding Request for Information on Small-Dollar Lending - RIN 3064-ZA04 (FDIC) Miscellaneous - The Federal Reserves Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (CFPB, House and Senate) Bank Secrecy Act (BSA) modernization - Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs) thresholds (CFPB, House and Senate) Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions and fintechs in CRA compliance, examination and enforcement (CFPB, House and Senate) Principals of GSE Reform (CFPB, House and Senate) Agriculture and rural America / rural economic development (CFPB, House and Senate) Expansionist Agenda of Credit Unions (CFPB, House and Senate) TRID and underwriting requirements under the ATR/QM (CFPB)

Miscellaneous - Agriculture and rural America / rural economic development (CFPB, House and Senate)

Miscellaneous - Tax credit to offset the cost of BSA compliance (CFPB, House and Senate) Expansionist Agenda of Credit Unions (CFPB, House and Senate) Expansionist Agenda of the Farm Credit System (CFPB, House and Senate)

Miscellaneous - The Federal Reserves Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (CFPB, House and Senate) Bank Secrecy Act (BSA) modernization - Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs) thresholds (CFPB, House and Senate) Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions and fintechs in CRA compliance, examination and enforcement (CFPB, House and Senate) Agriculture and rural America / rural economic development (CFPB, House and Senate) Expansionist Agenda of Credit Unions (CFPB, House and Senate) Expansionist Agenda of the Farm Credit System (CFPB, House and Senate) Small Business Data Collection (Section 1071 of the Dodd-Frank Act) (CFPB, House and Senate)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Legislation - Comment Letter to the OCC regarding Reforming the Community Reinvestment Act Regulatory Framework, Docket ID OCC-2018-0008 and RIN 1557-AE34 (House, OCC, Federal Reserve, FDIC) Miscellaneous - Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following - 201 (QM for portfolio loans), 103 (appraisal in rural areas), 104 (HMDA adjustments), 108 (escrow requirements), 109 (no wait 3 day TILA-RESPA mortgage disclosure), 201 (capital simplification), 202 (reciprocal deposits), 203 (Volcker Rule), 205 (short-form Call Report), 206 (Federal Savings Associations options), 201 (examination cycles), 214 (definitions and risk weights for HVCRE and ADC loans), 401 (enhanced supervision for certain HCs), 403 (treatment of muni obligations (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Tax credit to offset the cost of BSA compliance (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Expansionist Agenda of Credit Unions (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Expansionist Agenda of the Farm Credit System (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Access to Capital Restore the original intent of the Basel III rule Create a more accurate identification of systemic risk Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement Relieve community banks from excessive Securities and Exchange Commission rules Repeal the Collins Amendment for non-SIFIs Address minority bank capital challenges Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Legislation - H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance and USDA lending limits (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Senate version of H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance and USDA lending limits (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Letters - Comment Letter to the OCC regarding Reforming the Community Reinvestment Act Regulatory Framework, Docket ID OCC-2018-0008 and RIN 1557-AE34 (OCC) Miscellaneous - Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following - 201 (QM for portfolio loans), 103 (appraisal in rural areas), 104 (HMDA adjustments), 108 (escrow requirements), 109 (no wait 3 day TILA-RESPA mortgage disclosure), 201 (capital simplification), 202 (reciprocal deposits), 203 (Volcker Rule), 205 (short-form Call Report), 206 (Federal Savings Associations options), 201 (examination cycles), 214 (definitions and risk weights for HVCRE and ADC loans), 401 (enhanced supervision for certain HCs), 403 (treatment of muni obligations (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Bank Secrecy Act (BSA) modernization - Currency Transaction Report (CTR) threshold (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Tax credit to offset the cost of BSA compliance (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) The Federal Reserves Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Modification of the FDICs Deposit Rate Caps (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions in CRA compliance, examination and enforcement (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Agriculture and rural America / rural economic development (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Expansionist Agenda of Credit Unions (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Expansionist Agenda of the Farm Credit System (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) On-line business lending disclosures (Senate)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Access to Capital Restore the original intent of the Basel III rule Create a more accurate identification of systemic risk Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement Relieve community banks from excessive Securities and Exchange Commission rules Repeal the Collins Amendment for non-SIFIs Address minority bank capital challenges Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Mortgage Reform Create a safe harbor from onerous underwriting standards Establish relief from burdensome HMDA, escrow and appraisal requirements Preserve the ability for community banks to continue servicing mortgage loans Reform the closing process and accompanying paperwork Bank Oversight and Examination Strengthen accountability in bank exams and create a workable appeals process Reform bank oversight and examination to better target risk Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Legislation - H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance and USDA lending limits (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Senate version of H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance and USDA lending limits (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Letters - Comment Letter to the OCC regarding Reforming the Community Reinvestment Act Regulatory Framework, Docket ID OCC-2018-0008 and RIN 1557-AE34 (OCC) Letter to Congress regarding H.R. 2, the Agricultural Improvement Act of 2018 regarding crop insurance and conservations, expansion in foreign markets, and research and development (House and Senate) Comment Letter to the Federal Reserve Board regarding Potential Federal Reserve Actions to Support Interbank Settlement of faster Payments, Docket No. OP-1625 (Federal Reserve Board, Federal Reserve Bank of Cleveland, Kansas City) Miscellaneous - Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following - 201 (QM for portfolio loans), 103 (appraisal in rural areas), 104 (HMDA adjustments), 108 (escrow requirements), 109 (no wait 3 day TILA-RESPA mortgage disclosure), 201 (capital simplification), 202 (reciprocal deposits), 203 (Volcker Rule), 205 (short-form Call Report), 206 (Federal Savings Associations options), 201 (examination cycles), 214 (definitions and risk weights for HVCRE and ADC loans), 401 (enhanced supervision for certain HCs), 403 (treatment of muni obligations (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Bank Secrecy Act (BSA) modernization - Currency Transaction Report (CTR) threshold (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Tax credit to offset the cost of BSA compliance (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) The Federal Reserves Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Modification of the FDICs Deposit Rate Caps (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions in CRA compliance, examination and enforcement (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Principals of GSE Reform (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Agriculture and rural America / rural economic development (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Expansionist Agenda of Credit Unions (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Expansionist Agenda of the Farm Credit System (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Implementation of the Current Expected Credit Loss (CECL) model (OCC) On-line business lending disclosures (Senate) Short-form Call Report for first and third quarters of a year (Senate)

Letters - Comment Letter to the OCC regarding Reforming the Community Reinvestment Act Regulatory Framework, Docket ID OCC-2018-0008 and RIN 1557-AE34 (OCC) Miscellaneous - Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions in CRA compliance, examination and enforcement (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Agriculture and rural America / rural economic development (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Access to Capital Restore the original intent of the Basel III rule Create a more accurate identification of systemic risk Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement Relieve community banks from excessive Securities and Exchange Commission rules Repeal the Collins Amendment for non-SIFIs Address minority bank capital challenges Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Mortgage Reform Create a safe harbor from onerous underwriting standards Establish relief from burdensome HMDA, escrow and appraisal requirements Preserve the ability for community banks to continue servicing mortgage loans Reform the closing process and accompanying paperwork Bank Oversight and Examination Strengthen accountability in bank exams and create a workable appeals process Reform bank oversight and examination to better target risk Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Legislation - H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance and USDA lending limits (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Senate version of H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance and USDA lending limits (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Letters - Comment Letter to the OCC regarding Reforming the Community Reinvestment Act Regulatory Framework, Docket ID OCC-2018-0008 and RIN 1557-AE34 (OCC) Letter to Congress regarding H.R. 2, the Agricultural Improvement Act of 2018 regarding crop insurance and conservations, expansion in foreign markets, and research and development (House and Senate) Comment Letter to the Federal Reserve Board regarding Potential Federal Reserve Actions to Support Interbank Settlement of faster Payments, Docket No. OP-1625 (Federal Reserve Board, Federal Reserve Bank of Cleveland, Kansas City) Miscellaneous - Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following - 201 (QM for portfolio loans), 103 (appraisal in rural areas), 104 (HMDA adjustments), 108 (escrow requirements), 109 (no wait 3 day TILA-RESPA mortgage disclosure), 201 (capital simplification), 202 (reciprocal deposits), 203 (Volcker Rule), 205 (short-form Call Report), 206 (Federal Savings Associations options), 201 (examination cycles), 214 (definitions and risk weights for HVCRE and ADC loans), 401 (enhanced supervision for certain HCs), 403 (treatment of muni obligations (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Bank Secrecy Act (BSA) modernization - Currency Transaction Report (CTR) threshold (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Tax credit to offset the cost of BSA compliance (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) The Federal Reserves Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Modification of the FDICs Deposit Rate Caps (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions in CRA compliance, examination and enforcement (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Principals of GSE Reform (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Agriculture and rural America / rural economic development (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Expansionist Agenda of Credit Unions (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Expansionist Agenda of the Farm Credit System (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Implementation of the Current Expected Credit Loss (CECL) model (OCC) On-line business lending disclosures (Senate) Short-form Call Report for first and third quarters of a year (Senate)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Mortgage Reform Create a safe harbor from onerous underwriting standards Establish relief from burdensome HMDA, escrow and appraisal requirements Preserve the ability for community banks to continue servicing mortgage loans Reform the closing process and accompanying paperwork Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Letters - Comment Letter to the OCC regarding Reforming the Community Reinvestment Act Regulatory Framework, Docket ID OCC-2018-0008 and RIN 1557-AE34 (OCC) Miscellaneous - Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following - 201 (QM for portfolio loans), 103 (appraisal in rural areas), 104 (HMDA adjustments), 108 (escrow requirements), 109 (no wait 3 day TILA-RESPA mortgage disclosure), 201 (capital simplification), 202 (reciprocal deposits), 203 (Volcker Rule), 205 (short-form Call Report), 206 (Federal Savings Associations options), 201 (examination cycles), 214 (definitions and risk weights for HVCRE and ADC loans), 401 (enhanced supervision for certain HCs), 403 (treatment of muni obligations (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Bank Secrecy Act (BSA) modernization - Currency Transaction Report (CTR) threshold (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) The Federal Reserves Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions in CRA compliance, examination and enforcement (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Principals of GSE Reform (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Agriculture and rural America / rural economic development (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Expansionist Agenda of Credit Unions (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Mortgage Reform Create a safe harbor from onerous underwriting standards Establish relief from burdensome HMDA, escrow and appraisal requirements Preserve the ability for community banks to continue servicing mortgage loans Reform the closing process and accompanying paperwork Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Letters - Comment Letter to the OCC regarding Reforming the Community Reinvestment Act Regulatory Framework, Docket ID OCC-2018-0008 and RIN 1557-AE34 (OCC) Miscellaneous - Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following - 201 (QM for portfolio loans), 103 (appraisal in rural areas), 104 (HMDA adjustments), 108 (escrow requirements), 109 (no wait 3 day TILA-RESPA mortgage disclosure), 201 (capital simplification), 202 (reciprocal deposits), 203 (Volcker Rule), 205 (short-form Call Report), 206 (Federal Savings Associations options), 201 (examination cycles), 214 (definitions and risk weights for HVCRE and ADC loans), 401 (enhanced supervision for certain HCs), 403 (treatment of muni obligations (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Bank Secrecy Act (BSA) modernization - Currency Transaction Report (CTR) threshold (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) The Federal Reserves Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions in CRA compliance, examination and enforcement (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Principals of GSE Reform (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Agriculture and rural America / rural economic development (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Expansionist Agenda of Credit Unions (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)

Letters - Comment Letter to the OCC regarding Reforming the Community Reinvestment Act Regulatory Framework, Docket ID OCC-2018-0008 and RIN 1557-AE34 (OCC) Miscellaneous - Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions in CRA compliance, examination and enforcement (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Agriculture and rural America / rural economic development (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Access to Capital Restore the original intent of the Basel III rule Create a more accurate identification of systemic risk Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement Relieve community banks from excessive Securities and Exchange Commission rules Repeal the Collins Amendment for non-SIFIs Address minority bank capital challenges Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Legislation - H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance and USDA lending limits (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Senate version of H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance and USDA lending limits (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Letters - Comment Letter to the OCC regarding Reforming the Community Reinvestment Act Regulatory Framework, Docket ID OCC-2018-0008 and RIN 1557-AE34 (OCC) Miscellaneous - Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following - 201 (QM for portfolio loans), 103 (appraisal in rural areas), 104 (HMDA adjustments), 108 (escrow requirements), 109 (no wait 3 day TILA-RESPA mortgage disclosure), 201 (capital simplification), 202 (reciprocal deposits), 203 (Volcker Rule), 205 (short-form Call Report), 206 (Federal Savings Associations options), 201 (examination cycles), 214 (definitions and risk weights for HVCRE and ADC loans), 401 (enhanced supervision for certain HCs), 403 (treatment of muni obligations (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Bank Secrecy Act (BSA) modernization - Currency Transaction Report (CTR) threshold (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Tax credit to offset the cost of BSA compliance (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) The Federal Reserves Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Modification of the FDICs Deposit Rate Caps (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions in CRA compliance, examination and enforcement (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Agriculture and rural America / rural economic development (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Expansionist Agenda of Credit Unions (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Expansionist Agenda of the Farm Credit System (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) On-line business lending disclosures (Senate)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Legislation - Comment Letter to the OCC regarding Reforming the Community Reinvestment Act Regulatory Framework, Docket ID OCC-2018-0008 and RIN 1557-AE34 (House, OCC, Federal Reserve, FDIC) Miscellaneous - Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following - 201 (QM for portfolio loans), 103 (appraisal in rural areas), 104 (HMDA adjustments), 108 (escrow requirements), 109 (no wait 3 day TILA-RESPA mortgage disclosure), 201 (capital simplification), 202 (reciprocal deposits), 203 (Volcker Rule), 205 (short-form Call Report), 206 (Federal Savings Associations options), 201 (examination cycles), 214 (definitions and risk weights for HVCRE and ADC loans), 401 (enhanced supervision for certain HCs), 403 (treatment of muni obligations (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Tax credit to offset the cost of BSA compliance (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Expansionist Agenda of Credit Unions (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Expansionist Agenda of the Farm Credit System (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Access to Capital Restore the original intent of the Basel III rule Create a more accurate identification of systemic risk Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement Relieve community banks from excessive Securities and Exchange Commission rules Repeal the Collins Amendment for non-SIFIs Address minority bank capital challenges Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Mortgage Reform Create a safe harbor from onerous underwriting standards Establish relief from burdensome HMDA, escrow and appraisal requirements Preserve the ability for community banks to continue servicing mortgage loans Reform the closing process and accompanying paperwork Bank Oversight and Examination Strengthen accountability in bank exams and create a workable appeals process Reform bank oversight and examination to better target risk Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Legislation - H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance and USDA lending limits (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Senate version of H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance and USDA lending limits (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Letters - Comment Letter to the OCC regarding Reforming the Community Reinvestment Act Regulatory Framework, Docket ID OCC-2018-0008 and RIN 1557-AE34 (OCC) Letter to Congress regarding H.R. 2, the Agricultural Improvement Act of 2018 regarding crop insurance and conservations, expansion in foreign markets, and research and development (House and Senate) Comment Letter to the Federal Reserve Board regarding Potential Federal Reserve Actions to Support Interbank Settlement of faster Payments, Docket No. OP-1625 (Federal Reserve Board, Federal Reserve Bank of Cleveland, Kansas City) Miscellaneous - Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following - 201 (QM for portfolio loans), 103 (appraisal in rural areas), 104 (HMDA adjustments), 108 (escrow requirements), 109 (no wait 3 day TILA-RESPA mortgage disclosure), 201 (capital simplification), 202 (reciprocal deposits), 203 (Volcker Rule), 205 (short-form Call Report), 206 (Federal Savings Associations options), 201 (examination cycles), 214 (definitions and risk weights for HVCRE and ADC loans), 401 (enhanced supervision for certain HCs), 403 (treatment of muni obligations (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Bank Secrecy Act (BSA) modernization - Currency Transaction Report (CTR) threshold (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Tax credit to offset the cost of BSA compliance (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) The Federal Reserves Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Modification of the FDICs Deposit Rate Caps (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions in CRA compliance, examination and enforcement (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Principals of GSE Reform (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Agriculture and rural America / rural economic development (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Expansionist Agenda of Credit Unions (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Expansionist Agenda of the Farm Credit System (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Implementation of the Current Expected Credit Loss (CECL) model (OCC) On-line business lending disclosures (Senate) Short-form Call Report for first and third quarters of a year (Senate)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Legislation - H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance and USDA lending limits (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Senate version of H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance and USDA lending limits (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Letters - Comment Letter to the OCC regarding Reforming the Community Reinvestment Act Regulatory Framework, Docket ID OCC-2018-0008 and RIN 1557-AE34 (OCC) Letter to Congress regarding H.R. 2, the Agricultural Improvement Act of 2018 regarding crop insurance and conservations, expansion in foreign markets, and research and development (House and Senate) Miscellaneous - Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following - 201 (QM for portfolio loans), 103 (appraisal in rural areas), 104 (HMDA adjustments), 108 (escrow requirements), 109 (no wait 3 day TILA-RESPA mortgage disclosure), 201 (capital simplification), 202 (reciprocal deposits), 203 (Volcker Rule), 205 (short-form Call Report), 206 (Federal Savings Associations options), 201 (examination cycles), 214 (definitions and risk weights for HVCRE and ADC loans), 401 (enhanced supervision for certain HCs), 403 (treatment of muni obligations (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) The Federal Reserves Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions in CRA compliance, examination and enforcement (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Principals of GSE Reform (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Agriculture and rural America / rural economic development (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA) Expansionist Agenda of the Farm Credit System (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)

Miscellaneous - Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following) Increasing exemption thresholds for Home Mortgage Disclosure Act (HMDA) reporting; Granting Qualified Mortgage (QM) status for portfolio mortgage loans at most community banks; Exempting certain community bank loans from escrow requirements; Simplifying community bank capital requirements; Increasing eligibility for a short-form Call Report to restore proportionality to quarterly reporting; Expanding eligibility for the 18-month regulatory examination cycle; Easing appraisal requirements to facilitate mortgage credit in local communities; Exempting most community banks from the Volcker Rule; Expanding access to the Federal Reserves Small Bank Holding Company Policy Statement to help more community banks build capital; Improving regulatory treatment of reciprocal deposits and certain municipal securities; and Section 401 - SIFI thresholds) (House, Senate, OCC) Agriculture and rural America / rural economic development (House, Senate, OCC)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate, OCC) Legislation - H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance (House, OCC) Senate version of H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance (Senate, OCC) Letters - Letter to the U.S. Department of the Treasury regarding U.S. Postal Service reform and banking proposal (U.S. Treasury) Miscellaneous - Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following) Increasing exemption thresholds for Home Mortgage Disclosure Act (HMDA) reporting; Granting Qualified Mortgage (QM) status for portfolio mortgage loans at most community banks; Exempting certain community bank loans from escrow requirements; Simplifying community bank capital requirements; Increasing eligibility for a short-form Call Report to restore proportionality to quarterly reporting; Expanding eligibility for the 18-month regulatory examination cycle; Easing appraisal requirements to facilitate mortgage credit in local communities; Exempting most community banks from the Volcker Rule; Expanding access to the Federal Reserves Small Bank Holding Company Policy Statement to help more community banks build capital; Improving regulatory treatment of reciprocal deposits and certain municipal securities; and Section 401 - SIFI thresholds) (House, Senate, OCC) Expansionist Agenda of the Farm Credit System (House, Senate, OCC) Cybersecurity and additional regulatory burden on community banks (House) Small business data collection under the Dodd-Frank Act - Section 1071 (House, Senate, OCC) Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions in CRA compliance, examination and enforcement (House, Senate, OCC) Tax credits or deductions for lending to low- and middle-income individuals, businesses, farmers and ranchers (House, Senate, OCC) The Federal Reserves Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (House, Senate, OCC) Principals of GSE Reform (House, Senate, OCC) Agriculture and rural America / rural economic development (House, Senate, OCC) Federal/State issues in banking the business of marijuana (House) Home Mortgage Disclosure Act (HMDA) reporting regulatory relief (House)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Mortgage Reform Create a safe harbor from onerous underwriting standards Establish relief from burdensome HMDA, escrow and appraisal requirements Preserve the ability for community banks to continue servicing mortgage loans Reform the closing process and accompanying paperwork Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs (House, Senate, OCC) Letters - Letter to the U.S. Department of the Treasury regarding U.S. Postal Service reform and banking proposal (U.S. Treasury) Comment Letter to Department of Housing and Urban Development (HUD) regarding Advance Notice of Proposed Rulemaking: Reconsideration of HUDs Implementation of the Fair Housing Acts Disparate Impact Standard; Docket No. FR-6111-A-01 and RIN 2529-ZA01 Action Alerts - Action Alert regarding HUDs implementation of the Fair Housing Acts Disparate Impact Standard (HUD) Miscellaneous - Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following) Increasing exemption thresholds for Home Mortgage Disclosure Act (HMDA) reporting; Granting Qualified Mortgage (QM) status for portfolio mortgage loans at most community banks; Exempting certain community bank loans from escrow requirements; Simplifying community bank capital requirements; Increasing eligibility for a short-form Call Report to restore proportionality to quarterly reporting; Expanding eligibility for the 18-month regulatory examination cycle; Easing appraisal requirements to facilitate mortgage credit in local communities; Exempting most community banks from the Volcker Rule; Expanding access to the Federal Reserves Small Bank Holding Company Policy Statement to help more community banks build capital; Improving regulatory treatment of reciprocal deposits and certain municipal securities; and Section 401 - SIFI thresholds) (House, Senate, OCC) Bank Secrecy Act (BSA) modernization - Currency Transaction Report (CTR) threshold (House, Senate, OCC) Small business data collection under the Dodd-Frank Act - Section 1071 (House, Senate, OCC) Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions in CRA compliance, examination and enforcement (House, Senate, OCC) Tax credits or deductions for lending to low- and middle-income individuals, businesses, farmers and ranchers (House, Senate, OCC) The Federal Reserves Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (House, Senate, OCC) Principals of GSE Reform (House, Senate, OCC) Agriculture and rural America / rural economic development (House, Senate, OCC) Expansionist Agenda of Credit Unions (House, Senate, OCC) Cybersecurity and additional regulatory burden on community banks (House) Home Mortgage Disclosure Act (HMDA) reporting regulatory relief (House)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Access to Capital Restore the original intent of the Basel III rule Create a more accurate identification of systemic risk Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement Relieve community banks from excessive Securities and Exchange Commission rules Repeal the Collins Amendment for non-SIFIs Address minority bank capital challenges Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Mortgage Reform Create a safe harbor from onerous underwriting standards Establish relief from burdensome HMDA, escrow and appraisal requirements Preserve the ability for community banks to continue servicing mortgage loans Reform the closing process and accompanying paperwork Bank Oversight and Examination Strengthen accountability in bank exams and create a workable appeals process Reform bank oversight and examination to better target risk Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate, OCC) Legislation - H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance (House, OCC) Senate version of H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance (Senate, OCC) Letters - Letter to the U.S. Department of the Treasury regarding U.S. Postal Service reform and banking proposal (U.S. Treasury) Comment Letter to Department of Housing and Urban Development (HUD) regarding Advance Notice of Proposed Rulemaking: Reconsideration of HUDs Implementation of the Fair Housing Acts Disparate Impact Standard; Docket No. FR-6111-A-01 and RIN 2529-ZA01 Letter to the Federal Deposit Insurance Corporation (FDIC) regarding regulations on brokered deposits (Part 337.6 of the FDIC Rules and Regulations) that impact less than well capitalized banks (FDIC, Federal Reserve, OCC) Action Alerts - Action Alert regarding HUDs implementation of the Fair Housing Acts Disparate Impact Standard (HUD) Miscellaneous - Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following) Increasing exemption thresholds for Home Mortgage Disclosure Act (HMDA) reporting; Granting Qualified Mortgage (QM) status for portfolio mortgage loans at most community banks; Exempting certain community bank loans from escrow requirements; Simplifying community bank capital requirements; Increasing eligibility for a short-form Call Report to restore proportionality to quarterly reporting; Expanding eligibility for the 18-month regulatory examination cycle; Easing appraisal requirements to facilitate mortgage credit in local communities; Exempting most community banks from the Volcker Rule; Expanding access to the Federal Reserves Small Bank Holding Company Policy Statement to help more community banks build capital; Improving regulatory treatment of reciprocal deposits and certain municipal securities; and Section 401 - SIFI thresholds) (House, Senate, OCC) Bank Secrecy Act (BSA) modernization - Currency Transaction Report (CTR) threshold (House, Senate, OCC) Tax credit to offset the cost of BSA compliance (House, Senate, OCC) Small business date collection under the Dodd-Frank Act - Section 1071 (House, Senate, OCC) Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions in CRA compliance, examination and enforcement (House, Senate, OCC) Tax credits or deductions for lending to low- and middle-income individuals, businesses, farmers and ranchers (House, Senate, OCC) The Federal Reserves Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (House, Senate, OCC) Principals of GSE Reform (House, Senate, OCC) Agriculture and rural America / rural economic development (House, Senate, OCC) Expansionist Agenda of Credit Unions (House, Senate, OCC) Expansionist Agenda of the Farm Credit System (House, Senate, OCC) Federal Reserve Board nominee Michelle Bowman (Senate) Cybersecurity and additional regulatory burden on community banks (House) Federal/State issues in banking the business of marijuana (House) Home Mortgage Disclosure Act (HMDA) reporting regulatory relief (House) Beneficial ownership rule regulatory relief (House)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate, OCC) Miscellaneous - Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following) Increasing exemption thresholds for Home Mortgage Disclosure Act (HMDA) reporting; Granting Qualified Mortgage (QM) status for portfolio mortgage loans at most community banks; Exempting certain community bank loans from escrow requirements; Simplifying community bank capital requirements; Increasing eligibility for a short-form Call Report to restore proportionality to quarterly reporting; Expanding eligibility for the 18-month regulatory examination cycle; Easing appraisal requirements to facilitate mortgage credit in local communities; Exempting most community banks from the Volcker Rule; Expanding access to the Federal Reserves Small Bank Holding Company Policy Statement to help more community banks build capital; Improving regulatory treatment of reciprocal deposits and certain municipal securities; and Section 401 - SIFI thresholds) (House, Senate, OCC) Tax credit to offset the cost of BSA compliance (House, Senate, OCC) Tax credits or deductions for lending to low- and middle-income individuals, businesses, farmers and ranchers (House, Senate, OCC) Expansionist Agenda of Credit Unions (House, Senate, OCC) Expansionist Agenda of the Farm Credit System (House, Senate, OCC)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Access to Capital Restore the original intent of the Basel III rule Create a more accurate identification of systemic risk Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement Relieve community banks from excessive Securities and Exchange Commission rules Repeal the Collins Amendment for non-SIFIs Address minority bank capital challenges Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Mortgage Reform Create a safe harbor from onerous underwriting standards Establish relief from burdensome HMDA, escrow and appraisal requirements Preserve the ability for community banks to continue servicing mortgage loans Reform the closing process and accompanying paperwork Bank Oversight and Examination Strengthen accountability in bank exams and create a workable appeals process Reform bank oversight and examination to better target risk Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate, OCC) Legislation - H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance (House, OCC) Senate version of H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance (Senate, OCC) Letters - Letter to the U.S. Department of the Treasury regarding U.S. Postal Service reform and banking proposal (U.S. Treasury) Comment Letter to Department of Housing and Urban Development (HUD) regarding Advance Notice of Proposed Rulemaking: Reconsideration of HUDs Implementation of the Fair Housing Acts Disparate Impact Standard; Docket No. FR-6111-A-01 and RIN 2529-ZA01 Letter to the Federal Deposit Insurance Corporation (FDIC) regarding regulations on brokered deposits (Part 337.6 of the FDIC Rules and Regulations) that impact less than well capitalized banks (FDIC, Federal Reserve, OCC) Action Alerts - Action Alert regarding HUDs implementation of the Fair Housing Acts Disparate Impact Standard (HUD) Miscellaneous - Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following) Increasing exemption thresholds for Home Mortgage Disclosure Act (HMDA) reporting; Granting Qualified Mortgage (QM) status for portfolio mortgage loans at most community banks; Exempting certain community bank loans from escrow requirements; Simplifying community bank capital requirements; Increasing eligibility for a short-form Call Report to restore proportionality to quarterly reporting; Expanding eligibility for the 18-month regulatory examination cycle; Easing appraisal requirements to facilitate mortgage credit in local communities; Exempting most community banks from the Volcker Rule; Expanding access to the Federal Reserves Small Bank Holding Company Policy Statement to help more community banks build capital; Improving regulatory treatment of reciprocal deposits and certain municipal securities; and Section 401 - SIFI thresholds) (House, Senate, OCC) Bank Secrecy Act (BSA) modernization - Currency Transaction Report (CTR) threshold (House, Senate, OCC) Tax credit to offset the cost of BSA compliance (House, Senate, OCC) Small business data collection under the Dodd-Frank Act - Section 1071 (House, Senate, OCC) Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions in CRA compliance, examination and enforcement (House, Senate, OCC) Tax credits or deductions for lending to low- and middle-income individuals, businesses, farmers and ranchers (House, Senate, OCC) The Federal Reserves Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (House, Senate, OCC) Principals of GSE Reform (House, Senate, OCC) Agriculture and rural America / rural economic development (House, Senate, OCC) Expansionist Agenda of Credit Unions (House, Senate, OCC) Expansionist Agenda of the Farm Credit System (House, Senate, OCC) Federal Reserve Board nominee Michelle Bowman (Senate) Cybersecurity and additional regulatory burden on community banks (House) Federal/State issues in banking the business of marijuana (House) Home Mortgage Disclosure Act (HMDA) reporting regulatory relief (House) Beneficial ownership rule regulatory relief (House)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Access to Capital Restore the original intent of the Basel III rule Create a more accurate identification of systemic risk Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement Relieve community banks from excessive Securities and Exchange Commission rules Repeal the Collins Amendment for non-SIFIs Address minority bank capital challenges Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Mortgage Reform Create a safe harbor from onerous underwriting standards Establish relief from burdensome HMDA, escrow and appraisal requirements Preserve the ability for community banks to continue servicing mortgage loans Reform the closing process and accompanying paperwork Bank Oversight and Examination Strengthen accountability in bank exams and create a workable appeals process Reform bank oversight and examination to better target risk Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate) Legislation - S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular: Increasing exemption thresholds for Home Mortgage Disclosure Act (HMDA) reporting; Granting Qualified Mortgage (QM) status for portfolio mortgage loans at most community banks; Exempting certain community bank loans from escrow requirements; Simplifying community bank capital requirements; Increasing eligibility for a short-form Call Report to restore proportionality to quarterly reporting; Expanding eligibility for the 18-month regulatory examination cycle; Easing appraisal requirements to facilitate mortgage credit in local communities; Exempting most community banks from the Volcker Rule; Expanding access to the Federal Reserves Small Bank Holding Company Policy Statement to help more community banks build capital; Improving regulatory treatment of reciprocal deposits and certain municipal securities; and Section 401 - SIFI thresholds) (Senate, House, FDIC) H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance (House) Senate version of H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance (Senate) Letters - Letter to the Federal Reserve (with copies to FDIC, OCC and House) on the Feds Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (Federal Reserve, FDIC, OCC and House) Comment Letter to the Federal Housing Finance Agency (FHFA) regarding Proposed Rulemaking and Request for Comments on Affordable Housing Program (AHP) Amendments (RIN 2590-AA83) Action Alerts - Action Alert regarding passage of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (House) Action Alert regarding crop insurance in the Senate version of H.R. 2 - Agricultural Improvement Act of 2018 (The Farm Bill) (Senate) Miscellaneous - Implementation timeline for S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (Federal Reserve, FDIC, OCC) Bank Secrecy Act (BSA) modernization - Currency Transaction Report (CTR) threshold (House, Senate) Expansionist Agenda of Credit Unions (House, Senate) Expansionist Agenda of the Farm Credit System (House, Senate) Principals of GSE Reform (House, Senate) The impact of fintechs on community banks and the financial system including blockchain and Bitcoin, the opportunities and liabilities of consumer data sharing, evolution of the payment systems and payment systems improvements, Modernization of the Community Reinvestment Act (CRA) and the National Rate Cap on Deposits (FDIC)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate) Legislation - S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular: Increasing exemption thresholds for Home Mortgage Disclosure Act (HMDA) reporting; Granting Qualified Mortgage (QM) status for portfolio mortgage loans at most community banks; Exempting certain community bank loans from escrow requirements; Simplifying community bank capital requirements; Increasing eligibility for a short-form Call Report to restore proportionality to quarterly reporting; Expanding eligibility for the 18-month regulatory examination cycle; Easing appraisal requirements to facilitate mortgage credit in local communities; Exempting most community banks from the Volcker Rule; Expanding access to the Federal Reserves Small Bank Holding Company Policy Statement to help more community banks build capital; Improving regulatory treatment of reciprocal deposits and certain municipal securities; and Section 401 - SIFI thresholds) (Senate, House, FDIC) H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance (House) Senate version of H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance (Senate) Letters - Letter to the Federal Reserve (with copies to FDIC, OCC and House) on the Feds Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (Federal Reserve, FDIC, OCC and House) Comment Letter to the Federal Housing Finance Agency (FHFA) regarding Proposed Rulemaking and Request for Comments on Affordable Housing Program (AHP) Amendments (RIN 2590-AA83) Action Alerts - Action Alert regarding passage of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (House) Action Alert regarding crop insurance in the Senate version of H.R. 2 - Agricultural Improvement Act of 2018 (The Farm Bill) (Senate) Miscellaneous - Implementation timeline for S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (Federal Reserve, FDIC, OCC) Bank Secrecy Act (BSA) modernization - Currency Transaction Report (CTR) threshold (House, Senate) Expansionist Agenda of Credit Unions (House, Senate) Expansionist Agenda of the Farm Credit System (House, Senate) Principals of GSE Reform (House, Senate) The impact of fintechs on community banks and the financial system including blockchain and Bitcoin, the opportunities and liabilities of consumer data sharing, evolution of the payment systems and payment systems improvements, Modernization of the Community Reinvestment Act (CRA) and the National Rate Cap on Deposits (FDIC)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Mortgage Reform Create a safe harbor from onerous underwriting standards Establish relief from burdensome HMDA, escrow and appraisal requirements Preserve the ability for community banks to continue servicing mortgage loans Reform the closing process and accompanying paperwork Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs (House, Senate) Legislation - S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular: Increasing exemption thresholds for Home Mortgage Disclosure Act (HMDA) reporting; Granting Qualified Mortgage (QM) status for portfolio mortgage loans at most community banks; Exempting certain community bank loans from escrow requirements; Simplifying community bank capital requirements; Increasing eligibility for a short-form Call Report to restore proportionality to quarterly reporting; Expanding eligibility for the 18-month regulatory examination cycle; Easing appraisal requirements to facilitate mortgage credit in local communities; Exempting most community banks from the Volcker Rule; Expanding access to the Federal Reserves Small Bank Holding Company Policy Statement to help more community banks build capital; Improving regulatory treatment of reciprocal deposits and certain municipal securities; and Section 401 - SIFI thresholds) (Senate, House, FDIC) Letters - Letter to the Federal Reserve (with copies to FDIC, OCC and House) on the Feds Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (Federal Reserve, FDIC, OCC and House) Comment Letter to the Federal Housing Finance Agency (FHFA) regarding proposed rulemaking and request for comments on Affordable Housing Program (AHP) Amendments (RIN 2590-AA83) Action Alerts - Action Alert regarding passage of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (House) Miscellaneous - Implementation timeline for S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (Federal Reserve, FDIC, OCC) Bank Secrecy Act (BSA) modernization - Currency Transaction Report (CTR) threshold (House, Senate) Expansionist Agenda of Credit Unions (House, Senate) Principals of GSE Reform (House, Senate) The impact of fintechs on community banks and the financial system including blockchain and Bitcoin, the opportunities and liabilities of consumer data sharing, evolution of the payment systems and payment systems improvements, Modernization of the Community Reinvestment Act (CRA) and the National Rate Cap on Deposits (FDIC)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Access to Capital Restore the original intent of the Basel III rule Create a more accurate identification of systemic risk Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement Relieve community banks from excessive Securities and Exchange Commission rules Repeal the Collins Amendment for non-SIFIs Address minority bank capital challenges Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate) Legislation - S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular: Increasing exemption thresholds for Home Mortgage Disclosure Act (HMDA) reporting; Granting Qualified Mortgage (QM) status for portfolio mortgage loans at most community banks; Exempting certain community bank loans from escrow requirements; Simplifying community bank capital requirements; Increasing eligibility for a short-form Call Report to restore proportionality to quarterly reporting; Expanding eligibility for the 18-month regulatory examination cycle; Easing appraisal requirements to facilitate mortgage credit in local communities; Exempting most community banks from the Volcker Rule; Expanding access to the Federal Reserves Small Bank Holding Company Policy Statement to help more community banks build capital; Improving regulatory treatment of reciprocal deposits and certain municipal securities; and Section 401 - SIFI thresholds) (Senate, House, FDIC) H.R. 2 - Agricultural Improvement Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance (House) Senate version of H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance (Senate) Letters - Letter to the Federal Reserve (with copies to FDIC, OCC and House) on the Feds Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (Federal Reserve, FDIC, OCC and House) Action Alerts - Action Alert regarding passage of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (House) Action Alert regarding crop insurance in the Senate version of H.R. 2 - Agricultural Improvement Act of 2018 (The Farm Bill) (Senate) Miscellaneous - Implementation timeline for S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (Federal Reserve, FDIC, OCC) Bank Secrecy Act (BSA) modernization - Currency Transaction Report (CTR) threshold (House, Senate) Expansionist Agenda of Credit Unions (House, Senate) Expansionist Agenda of the Farm Credit System (House, Senate) The impact of fintechs on community banks and the financial system including blockchain and Bitcoin, the opportunities and liabilities of consumer data sharing, evolution of the payment systems and payment systems improvements, Modernization of the Community Reinvestment Act (CRA) and the National Rate Cap on Deposits (FDIC)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Access to Capital Restore the original intent of the Basel III rule Create a more accurate identification of systemic risk Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement Relieve community banks from excessive Securities and Exchange Commission rules Repeal the Collins Amendment for non-SIFIs Address minority bank capital challenges Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Mortgage Reform Create a safe harbor from onerous underwriting standards Establish relief from burdensome HMDA, escrow and appraisal requirements Preserve the ability for community banks to continue servicing mortgage loans Reform the closing process and accompanying paperwork Bank Oversight and Examination Strengthen accountability in bank exams and create a workable appeals process Reform bank oversight and examination to better target risk Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate) Legislation - S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular: Increasing exemption thresholds for Home Mortgage Disclosure Act (HMDA) reporting; Granting Qualified Mortgage (QM) status for portfolio mortgage loans at most community banks; Exempting certain community bank loans from escrow requirements; Simplifying community bank capital requirements; Increasing eligibility for a short-form Call Report to restore proportionality to quarterly reporting; Expanding eligibility for the 18-month regulatory examination cycle; Easing appraisal requirements to facilitate mortgage credit in local communities; Exempting most community banks from the Volcker Rule; Expanding access to the Federal Reserves Small Bank Holding Company Policy Statement to help more community banks build capital; Improving regulatory treatment of reciprocal deposits and certain municipal securities; and Section 401 - SIFI thresholds) (Senate, House, FDIC) H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance (House) Senate version of H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance (Senate) Letters - Letter to the Federal Reserve (with copies to FDIC, OCC and House) on the Feds Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (Federal Reserve, FDIC, OCC and House) Comment Letter to the Federal Housing Finance Agency (FHFA) regarding Proposed Rulemaking and Request for Comments on Affordable Housing Program (AHP) Amendments (RIN 2590-AA83) Action Alerts - Action Alert regarding passage of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (House) Action Alert regarding crop insurance in the Senate version of H.R. 2 - Agricultural Improvement Act of 2018 (The Farm Bill) (Senate) Miscellaneous - Implementation timeline for S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (Federal Reserve, FDIC, OCC) Bank Secrecy Act (BSA) modernization - Currency Transaction Report (CTR) threshold (House, Senate) Expansionist Agenda of Credit Unions (House, Senate) Expansionist Agenda of the Farm Credit System (House, Senate) Principals of GSE Reform (House, Senate) The impact of fintechs on community banks and the financial system including blockchain and Bitcoin, the opportunities and liabilities of consumer data sharing, evolution of the payment systems and payment systems improvements, Modernization of the Community Reinvestment Act (CRA) and the National Rate Cap on Deposits (FDIC)

Legislation - S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular: Increasing exemption thresholds for Home Mortgage Disclosure Act (HMDA) reporting; Granting Qualified Mortgage (QM) status for portfolio mortgage loans at most community banks; Exempting certain community bank loans from escrow requirements; Simplifying community bank capital requirements; Increasing eligibility for a short-form Call Report to restore proportionality to quarterly reporting; Expanding eligibility for the 18-month regulatory examination cycle; Easing appraisal requirements to facilitate mortgage credit in local communities; Exempting most community banks from the Volcker Rule; Expanding access to the Federal Reserves Small Bank Holding Company Policy Statement to help more community banks build capital; Improving regulatory treatment of reciprocal deposits and certain municipal securities; and Section 401 - SIFI thresholds) (Senate, House, FDIC) Action Alerts - Action Alert regarding passage of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (House) Miscellaneous - Implementation timeline for S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (Federal Reserve, FDIC, OCC)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate, Federal Reserve) CBAI 2017 Federal Policy Priorities New Farm Bill and abolishing (or reigning-in) the Farm Credit System, crop insurance, USDA loan guarantee programs - volume caps and additional funding - Expansionist agenda of the Farm Credit System (FCS), the benefits of their Government Sponsored Enterprise (GSE) status, funding and tax advantages of the FCS, direct competition with community banks, cheerleader regulator - Farm Credit Administration (FCA), blatant discrimination against rural community banks, following its narrow historic mission of serving bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives, Joint House/Senate hearings, abolish or subject FCS to funding restrictions, taxation and rigorous oversight and regulation. Mortgage lending and housing finance reform - Community banks strength of their reputation, incentive to make fair and reasonable loans, and do not need prescriptive regulations to compel them to do what is right for their customers Community bank loans held in portfolio receiving automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs), increase in the small servicer exemption, increase in HMDA reporting levels, a safe harbor from the newly implemented TRID, accommodations for community banks to provide greater flexibility in serving the needs of their customers and communities, (particularly in rural areas, and urges expanding the definition of underserved areas to include economically challenged areas), use of property evaluations completed by qualified bank staff in lieu of a residential property appraisal for any residential mortgage that a community bank originates and retains in its portfolio. Regarding the reform of the housing GSEs, the continued existence of an impartial secondary market for residential mortgages that is financially strong and reliable, some level of government involvement in the secondary market to ensure the continued flow of credit and market liquidity during periods of severe economic stress, reform that does not limit the full participation by community banks or disrupts the housing market, encouraging a return of private capital to reduce the reliance on government funding and help protect taxpayers from another bailout, sale of loans through an independent entity that does not compete with community banks, no appropriation of community bank customer data for the purpose of cross selling financial services, the Federal Home Loan Banks preserved as a community bank access point (but not the only access point) to the national secondary market, the pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed, the 30-year fixed-rate mortgage for creditworthy customers in all markets, no further consolidation of the housing finance system that would result in mega banks and financial firms dominating the market. (House, Senate, Federal Reserve) Legislation - S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (community bank regulatory relief) (All sections) (Senate, House, Federal Reserve) Letters - CBAI Executive Committee letter regarding S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (Senate) Joint Illinois financial trade associations letter regarding S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (House, Senate) Action Alerts - Action Alert regarding passage of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (Senate) Second Action Alert regarding passage of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (HMDA) (Senate) Miscellaneous - Support for Agricultural and Rural America (House, Senate, Federal Reserve) Principals of GSE Reform (House, Senate, Federal Reserve) Expansionist Agenda of Credit Unions and the Farm Credit System (House, Senate, Federal Reserve) USDA guaranteed loan limits (House)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Access to Capital Restore the original intent of the Basel III rule Create a more accurate identification of systemic risk Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement Relieve community banks from excessive Securities and Exchange Commission rules Repeal the Collins Amendment for non-SIFIs Address minority bank capital challenges Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Mortgage Reform Create a safe harbor from onerous underwriting standards Establish relief from burdensome HMDA, escrow and appraisal requirements Preserve the ability for community banks to continue servicing mortgage loans Reform the closing process and accompanying paperwork Bank Oversight and Examination Strengthen accountability in bank exams and create a workable appeals process Reform bank oversight and examination to better target risk Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate, Federal Reserve) CBAI 2017 Federal Policy Priorities Meaningful regulatory relief, together with tiered regulation and supervision for community banks, as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity - See above. Regarding the implementation of regulatory initiatives - Special purpose fintech national bank charters by the OCC to financial technology companies Financial Accounting Standards Board (FASB) Current Expected Credit Loss Model (CECL) Consumer Financial Protection Bureaus (CFPB) proposed payday and vehicle title (small-dollar credit) lending rules De novo bank formation, the dual banking system, and charter choice The issue of too-big-to-fail banks and financial firms - protect our financial system, economy and taxpayers from future bailouts - Credible proposals to address TBTF and reduce the risks the mega banks poses to the financial system, economy and American taxpayers including those from: FDIC Vice Chairman Thomas Hoenig, Minneapolis Federal Reserve Chairman Neel Kashkari and Arthur Wilmarth - George Washington University Law School professor and a nationally recognized authority on bank regulation. These plans are in addition to a number of legislative proposals including a 21st century version of the original 1933 Glass-Steagall [separation of banking and commerce] Act. New Farm Bill and abolishing (or reigning-in) the Farm Credit System, crop insurance, USDA loan guarantee programs - volume caps and additional funding - Expansionist agenda of the Farm Credit System (FCS), the benefits of their Government Sponsored Enterprise (GSE) status, funding and tax advantages of the FCS, direct competition with community banks, cheerleader regulator - Farm Credit Administration (FCA), blatant discrimination against rural community banks, following its narrow historic mission of serving bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives, Joint House/Senate hearings, abolish or subject FCS to funding restrictions, taxation and rigorous oversight and regulation. Taxation of credit unions and their expansion of powers - Outdated original business model, straying from their founding mission, ignoring field of membership or common bond requirement, now provide the same financial services as community banks, expansionist agenda, cheerleader regulator - National Credit Union Administration, justification for federal tax-exempt status, blatant discrimination against tax-paying community banks, eliminate subsidies or pay fair share of income taxes. Enhanced data, cyber and payment card security (data security) - Wide-scale data security breaches at national retail chain stores and other entities, far-reaching and costly incidents resulting in reissuing credit and debit cards at a considerable cost. Community banks defense against cyber security threats, their role in securing data and personal information as a matter of good business practice and to comply with legal and regulatory requirements. Data security principals include the cost of data breaches borne by that party that caused the breach, all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards, a national data security breach and notification standard should replace the current patchwork of state laws, and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations. Community banks reliance on third party service providers (core data processors and subcontractors of technology service providers for example), broadening the regulatory supervision of these service providers to ensure they comply with nondisclosure and confidentiality requirements similar to existing requirements for community banks. Mortgage lending and housing finance reform - Community banks strength of their reputation, incentive to make fair and reasonable loans, and do not need prescriptive regulations to compel them to do what is right for their customers Community bank loans held in portfolio receiving automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs), increase in the small servicer exemption, increase in HMDA reporting levels, a safe harbor from the newly implemented TRID, accommodations for community banks to provide greater flexibility in serving the needs of their customers and communities, (particularly in rural areas, and urges expanding the definition of underserved areas to include economically challenged areas), use of property evaluations completed by qualified bank staff in lieu of a residential property appraisal for any residential mortgage that a community bank originates and retains in its portfolio. Regarding the reform of the housing GSEs, the continued existence of an impartial secondary market for residential mortgages that is financially strong and reliable, some level of government involvement in the secondary market to ensure the continued flow of credit and market liquidity during periods of severe economic stress, reform that does not limit the full participation by community banks or disrupts the housing market, encouraging a return of private capital to reduce the reliance on government funding and help protect taxpayers from another bailout, sale of loans through an independent entity that does not compete with community banks, no appropriation of community bank customer data for the purpose of cross selling financial services, the Federal Home Loan Banks preserved as a community bank access point (but not the only access point) to the national secondary market, the pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed, the 30-year fixed-rate mortgage for creditworthy customers in all markets, no further consolidation of the housing finance system that would result in mega banks and financial firms dominating the market. Consumer Financial Protection Bureau Reform - The Consumer Financial Protection Bureau (CFPB) use of its statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, focus of regulation of financial products on the mega banks and financial firms and the unregulated shadow financial industry, community bank flexibility to meet the unique needs of its customers, burdening community banks with additional and unnecessary regulatory requirements that could prevent them from serving their communities, a one-size-fits-all approach to CFPB regulations, influencing the marketplace behavior by targeting of financial institutions, products, services, practices deemed to be undesirable or inappropriate, replacing single-Director governance with a five-member commission, prudential regulators participation with the CFPB in the rule-writing process, and the Financial Stability Oversight Council (FSOC) power to veto CFPB rules. Maintain the Federal Home Loan Bank System - The regional structure, special functions and purposes of the FHLBs, the System remaining a financially sound, stable and reliable source of funding for its members, reliance upon it as the sole aggregator or securitizer of residential mortgages for community banks, the FHFA imposing an ongoing housing mission asset test on community financial institutions, rulemaking to restrict FHLB membership eligibility requirements. (House, Senate, Federal Reserve) Legislation - H.R. 4725 - Community Bank Reporting Relief Act (Call Reports) (All Sections) (House) H.R. 1115 - Modernizing American Manufacturing Bonds Act (All Sections) (House) S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (community bank regulatory relief) (All sections) (Senate, House, Federal Reserve) S. 2378 - Access Business Credit Act of 2018 (small business loan income tax relief) (All Sections) (Senate) H.R. 2890 and S. 2361 - Housing Opportunity Mortgage Expansion Act (captive insurance company membership in the FHLBs) (All Sections) (Senate) Letters - CBAI Executive Committee letter regarding S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (Senate) Joint Illinois financial trade associations letter regarding S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (House, Senate) Action Alerts - Action Alert regarding passage of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (Senate) Second Action Alert regarding passage of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (HMDA) (Senate) Miscellaneous - The impact of fintechs on community banks and the financial system, the opportunities and perils of consumer data sharing, evolution of the payment systems and payment systems improvements (Federal Reserve) The rapid rise of fintechs, how the pace of fintech development is different than prior technology developments, the different approaches taken by large versus small banks (go-it-alone or partner), opportunities for partnerships with fintechs, risk factors to consider in the development of a fintech strategy, the importance of communicating early and often with banks regulators, and the challenges of customer data sharing with fintechs (data ownership and rights, privacy concerns, and liability for mishandling and misuse), the recent changes in leaderships impact on the OCCs fintech initiatives, the status of the lawsuit against the OCC by the Conference of State Bank Supervisors challenging the OCCs authority to approve special purpose national bank charters for fintechs, coordination among regulators on fintech supervision and regulation, and the importance of the regulators sharing success stories or problems/issues as additional guidance for the community banks they regulate. (OCC) Electronic delivery of loan files to streamline examinations, the impact of fintechs on community banks and the financial system, the opportunities and perils of consumer data sharing, evolution of the payment systems and payment systems improvements (Federal Reserve) Community bank access to payment systems improvements (House, Senate, Federal Reserve) Principals of GSE Reform (House, Senate, Federal Reserve) Support for Agricultural and Rural America (House, Senate, Federal Reserve) USDA guaranteed loan limits (House) FinCEN beneficial ownership [identification] requirements (Senate) Expansionist Agenda of Credit Unions and the Farm Credit System (House, Senate, Federal Reserve)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Access to Capital Restore the original intent of the Basel III rule Create a more accurate identification of systemic risk Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement Relieve community banks from excessive Securities and Exchange Commission rules Repeal the Collins Amendment for non-SIFIs Address minority bank capital challenges Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate, Federal Reserve) CBAI 2017 Federal Policy Priorities Regarding the implementation of regulatory initiatives - Special purpose fintech national bank charters by the OCC to financial technology companies Taxation of credit unions and their expansion of powers - Outdated original business model, straying from their founding mission, ignoring field of membership or common bond requirement, now provide the same financial services as community banks, expansionist agenda, cheerleader regulator - National Credit Union Administration, justification for federal tax-exempt status, blatant discrimination against tax-paying community banks, eliminate subsidies or pay fair share of income taxes. Enhanced data, cyber and payment card security (data security) - Wide-scale data security breaches at national retail chain stores and other entities, far-reaching and costly incidents resulting in reissuing credit and debit cards at a considerable cost. Community banks defense against cyber security threats, their role in securing data and personal information as a matter of good business practice and to comply with legal and regulatory requirements. Data security principals include the cost of data breaches borne by that party that caused the breach, all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards, a national data security breach and notification standard should replace the current patchwork of state laws, and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations. Community banks reliance on third party service providers (core data processors and subcontractors of technology service providers for example), broadening the regulatory supervision of these service providers to ensure they comply with nondisclosure and confidentiality requirements similar to existing requirements for community banks. (House, Senate, Federal Reserve) Legislation - H.R. 1115 - Modernizing American Manufacturing Bonds Act (All Sections) (House) S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (community bank regulatory relief) (All sections) (Senate, House, Federal Reserve) Letters - CBAI Executive Committee letter regarding S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (Senate) Joint Illinois financial trade associations letter regarding S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (House, Senate) Action Alerts - Action Alert regarding passage of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (Senate) Miscellaneous - The impact of fintechs on community banks and the financial system, the opportunities and perils of consumer data sharing, evolution of the payment systems and payment systems improvements (Federal Reserve) The rapid rise of fintechs, how the pace of fintech development is different than prior technology developments, the different approaches taken by large versus small banks (go-it-alone or partner), opportunities for partnerships with fintechs, risk factors to consider in the development of a fintech strategy, the importance of communicating early and often with banks regulators, and the challenges of customer data sharing with fintechs (data ownership and rights, privacy concerns, and liability for mishandling and misuse), the recent changes in leaderships impact on the OCCs fintech initiatives, the status of the lawsuit against the OCC by the Conference of State Bank Supervisors challenging the OCCs authority to approve special purpose national bank charters for fintechs, coordination among regulators on fintech supervision and regulation, and the importance of the regulators sharing success stories or problems/issues as additional guidance for the community banks they regulate. (OCC) Support for Agricultural and Rural America (House, Senate, Federal Reserve) USDA guaranteed loan limits (House) FinCEN beneficial ownership [identification] requirements (Senate) Expansionist Agenda of Credit Unions and the Farm Credit System (House, Senate, Federal Reserve)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate, Federal Reserve) CBAI 2017 Federal Policy Priorities New Farm Bill and abolishing (or reigning-in) the Farm Credit System, crop insurance, USDA loan guarantee programs - volume caps and additional funding - Expansionist agenda of the Farm Credit System (FCS), the benefits of their Government Sponsored Enterprise (GSE) status, funding and tax advantages of the FCS, direct competition with community banks, cheerleader regulator - Farm Credit Administration (FCA), blatant discrimination against rural community banks, following its narrow historic mission of serving bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives, Joint House/Senate hearings, abolish or subject FCS to funding restrictions, taxation and rigorous oversight and regulation. Taxation of credit unions and oppose their expansion of powers - Outdated original business model, straying from their founding mission, ignoring field of membership or common bond requirement, now provide the same financial services as community banks, expansionist agenda, cheerleader regulator - National Credit Union Administration, justification for federal tax-exempt status, blatant discrimination against tax-paying community banks, eliminate subsidies or pay fair share of income taxes. (House, Senate, Federal Reserve) Legislation - H.R. 1115 - Modernizing American Manufacturing Bonds Act (All Sections) (House) S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (community bank regulatory relief) (All sections) (Senate, House, Federal Reserve) S. 2378 - Access Business Credit Act of 2018 (All Sections) (Senate) Letters - CBAI Executive Committee letter regarding S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (Senate) Joint Illinois financial trade associations letter regarding S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (House, Senate) Action Alerts - Action Alert regarding passage of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (Senate) Miscellaneous - Expansionist Agenda of Credit Unions and the Farm Credit System (House, Senate, Federal Reserve)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Access to Capital Restore the original intent of the Basel III rule Create a more accurate identification of systemic risk Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement Relieve community banks from excessive Securities and Exchange Commission rules Repeal the Collins Amendment for non-SIFIs Address minority bank capital challenges Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Mortgage Reform Create a safe harbor from onerous underwriting standards Establish relief from burdensome HMDA, escrow and appraisal requirements Preserve the ability for community banks to continue servicing mortgage loans Reform the closing process and accompanying paperwork Bank Oversight and Examination Strengthen accountability in bank exams and create a workable appeals process Reform bank oversight and examination to better target risk Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate, Federal Reserve) CBAI 2017 Federal Policy Priorities Meaningful regulatory relief, together with tiered regulation and supervision for community banks, as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity - See above. Regarding the implementation of regulatory initiatives - Special purpose fintech national bank charters by the OCC to financial technology companies Financial Accounting Standards Board (FASB) Current Expected Credit Loss Model (CECL) Consumer Financial Protection Bureaus (CFPB) proposed payday and vehicle title (small-dollar credit) lending rules De novo bank formation, the dual banking system, and charter choice The issue of too-big-to-fail banks and financial firms - protect our financial system, economy and taxpayers from future bailouts - Credible proposals to address TBTF and reduce the risks the mega banks poses to the financial system, economy and American taxpayers including those from: FDIC Vice Chairman Thomas Hoenig, Minneapolis Federal Reserve Chairman Neel Kashkari and Arthur Wilmarth - George Washington University Law School professor and a nationally recognized authority on bank regulation. These plans are in addition to a number of legislative proposals including a 21st century version of the original 1933 Glass-Steagall [separation of banking and commerce] Act. New Farm Bill and abolishing (or reigning-in) the Farm Credit System, crop insurance, USDA loan guarantee programs - volume caps and additional funding - Expansionist agenda of the Farm Credit System (FCS), the benefits of their Government Sponsored Enterprise (GSE) status, funding and tax advantages of the FCS, direct competition with community banks, cheerleader regulator - Farm Credit Administration (FCA), blatant discrimination against rural community banks, following its narrow historic mission of serving bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives, Joint House/Senate hearings, abolish or subject FCS to funding restrictions, taxation and rigorous oversight and regulation. Taxation of credit unions and their expansion of powers - Outdated original business model, straying from their founding mission, ignoring field of membership or common bond requirement, now provide the same financial services as community banks, expansionist agenda, cheerleader regulator - National Credit Union Administration, justification for federal tax-exempt status, blatant discrimination against tax-paying community banks, eliminate subsidies or pay fair share of income taxes. Enhanced data, cyber and payment card security (data security) - Wide-scale data security breaches at national retail chain stores and other entities, far-reaching and costly incidents resulting in reissuing credit and debit cards at a considerable cost. Community banks defense against cyber security threats, their role in securing data and personal information as a matter of good business practice and to comply with legal and regulatory requirements. Data security principals include the cost of data breaches borne by that party that caused the breach, all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards, a national data security breach and notification standard should replace the current patchwork of state laws, and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations. Community banks reliance on third party service providers (core data processors and subcontractors of technology service providers for example), broadening the regulatory supervision of these service providers to ensure they comply with nondisclosure and confidentiality requirements similar to existing requirements for community banks. Mortgage lending and housing finance reform - Community banks strength of their reputation, incentive to make fair and reasonable loans, and do not need prescriptive regulations to compel them to do what is right for their customers Community bank loans held in portfolio receiving automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs), increase in the small servicer exemption, increase in HMDA reporting levels, a safe harbor from the newly implemented TRID, accommodations for community banks to provide greater flexibility in serving the needs of their customers and communities, (particularly in rural areas, and urges expanding the definition of underserved areas to include economically challenged areas), use of property evaluations completed by qualified bank staff in lieu of a residential property appraisal for any residential mortgage that a community bank originates and retains in its portfolio. Regarding the reform of the housing GSEs, the continued existence of an impartial secondary market for residential mortgages that is financially strong and reliable, some level of government involvement in the secondary market to ensure the continued flow of credit and market liquidity during periods of severe economic stress, reform that does not limit the full participation by community banks or disrupts the housing market, encouraging a return of private capital to reduce the reliance on government funding and help protect taxpayers from another bailout, sale of loans through an independent entity that does not compete with community banks, no appropriation of community bank customer data for the purpose of cross selling financial services, the Federal Home Loan Banks preserved as a community bank access point (but not the only access point) to the national secondary market, the pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed, the 30-year fixed-rate mortgage for creditworthy customers in all markets, no further consolidation of the housing finance system that would result in mega banks and financial firms dominating the market. Consumer Financial Protection Bureau Reform - The Consumer Financial Protection Bureau (CFPB) use of its statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, focus of regulation of financial products on the mega banks and financial firms and the unregulated shadow financial industry, community bank flexibility to meet the unique needs of its customers, burdening community banks with additional and unnecessary regulatory requirements that could prevent them from serving their communities, a one-size-fits-all approach to CFPB regulations, influencing the marketplace behavior by targeting of financial institutions, products, services, practices deemed to be undesirable or inappropriate, replacing single-Director governance with a five-member commission, prudential regulators participation with the CFPB in the rule-writing process, and the Financial Stability Oversight Council (FSOC) power to veto CFPB rules. Maintain the Federal Home Loan Bank System - The regional structure, special functions and purposes of the FHLBs, the System remaining a financially sound, stable and reliable source of funding for its members, reliance upon it as the sole aggregator or securitizer of residential mortgages for community banks, the FHFA imposing an ongoing housing mission asset test on community financial institutions, rulemaking to restrict FHLB membership eligibility requirements. (House, Senate, Federal Reserve) Legislation - H.R. 4725 - Community Bank Reporting Relief Act (Call Reports) (All Sections) (House) H.R. 1115 - Modernizing American Manufacturing Bonds Act (All Sections) (House) S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (community bank regulatory relief) (All sections) (Senate, House, Federal Reserve) S. 2378 - Access Business Credit Act of 2018 (small business loan income tax relief) (All Sections) (Senate) H.R. 2890 and S. 2361 - Housing Opportunity Mortgage Expansion Act (captive insurance company membership in the FHLBs) (All Sections) (Senate) Letters - CBAI Executive Committee letter regarding S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (Senate) Joint Illinois financial trade associations letter regarding S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (House, Senate) Action Alerts - Action Alert regarding passage of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (Senate) Second Action Alert regarding passage of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (HMDA) (Senate) Miscellaneous - The impact of fintechs on community banks and the financial system, the opportunities and perils of consumer data sharing, evolution of the payment systems and payment systems improvements (Federal Reserve) The rapid rise of fintechs, how the pace of fintech development is different than prior technology developments, the different approaches taken by large versus small banks (go-it-alone or partner), opportunities for partnerships with fintechs, risk factors to consider in the development of a fintech strategy, the importance of communicating early and often with banks regulators, and the challenges of customer data sharing with fintechs (data ownership and rights, privacy concerns, and liability for mishandling and misuse), the recent changes in leaderships impact on the OCCs fintech initiatives, the status of the lawsuit against the OCC by the Conference of State Bank Supervisors challenging the OCCs authority to approve special purpose national bank charters for fintechs, coordination among regulators on fintech supervision and regulation, and the importance of the regulators sharing success stories or problems/issues as additional guidance for the community banks they regulate. (OCC) Electronic delivery of loan files to streamline examinations, the impact of fintechs on community banks and the financial system, the opportunities and perils of consumer data sharing, evolution of the payment systems and payment systems improvements (Federal Reserve) Community bank access to payment systems improvements (House, Senate, Federal Reserve) Principals of GSE Reform (House, Senate, Federal Reserve) Support for Agricultural and Rural America (House, Senate, Federal Reserve) USDA guaranteed loan limits (House) FinCEN beneficial ownership [identification] requirements (Senate) Expansionist Agenda of Credit Unions and the Farm Credit System (House, Senate, Federal Reserve)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Access to Capital Restore the original intent of the Basel III rule Create a more accurate identification of systemic risk Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement Relieve community banks from excessive Securities and Exchange Commission rules Repeal the Collins Amendment for non-SIFIs Address minority bank capital challenges Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate, OCC, FDIC, CFPB) CBAI 2017 Federal Policy Priorities Regarding the implementation of regulatory initiatives - Special purpose fintech national bank charters by the OCC to financial technology companies Taxation of credit unions and their expansion of powers - Outdated original business model, straying from their founding mission, ignoring field of membership or common bond requirement, now provide the same financial services as community banks, expansionist agenda, cheerleader regulator - National Credit Union Administration, justification for federal tax-exempt status, blatant discrimination against tax-paying community banks, eliminate subsidies or pay fair share of income taxes. Enhanced data, cyber and payment card security (data security) - Wide-scale data security breaches at national retail chain stores and other entities, far-reaching and costly incidents resulting in reissuing credit and debit cards at a considerable cost. Community banks defense against cyber security threats, their role in securing data and personal information as a matter of good business practice and to comply with legal and regulatory requirements. Data security principals include the cost of data breaches borne by that party that caused the breach, all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards, a national data security breach and notification standard should replace the current patchwork of state laws, and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations. Community banks reliance on third party service providers (core data processors and subcontractors of technology service providers for example), broadening the regulatory supervision of these service providers to ensure they comply with nondisclosure and confidentiality requirements similar to existing requirements for community banks. (House, Senate, OCC, FDIC, CFPB) Legislation - H.R. 2133 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEARR Act of 2017) - (regulatory relief) (All Sections) (House, OCC, CFPB, FDIC) S. 1002 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEAR Relief Act of 2017) (regulatory relief) (All Sections) (Senate, OCC, CFPB, FDIC) S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections except those regarding prudential standards applicable solely to banks over $10 billion in assets (Section 401) and credit unions (Section 105) (Senate and House) H.R. 1 - The Tax Cuts and Jobs Act (Sections particularly concerning the individual rate, corporate rate, Subchapter S pass through rate, mortgage servicing assets (13221), business interest deduction, mortgage interest deduction, state and local taxes (SALT), estate taxes, corporate Alternative Minimum Taxes (AMT), non-qualified deferred compensation plans, and deductions for FDIC premiums) (House and Senate) Action Alerts - Action Alert regarding Subchapter S (pass through rate) in tax reform legislation - H.R. 1, the Tax Cuts and Jobs Act (House and Senate) Second Action Alert regarding Subchapter S (pass through rate) in tax reform legislation - H.R. 1, the Tax Cuts and Jobs Act (House and Senate) Miscellaneous - Principals of Tax Relief and Reform (House, Senate, OCC, CFPB, FDIC) Support for Agricultural and Rural America (House, Senate, OCC, CFPB, FDIC) Expansionist Agenda of Credit Unions and the Farm Credit System (House, Senate, OCC, CFPB, FDIC)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Mortgage Reform Create a safe harbor from onerous underwriting standards Establish relief from burdensome HMDA, escrow and appraisal requirements Preserve the ability for community banks to continue servicing mortgage loans Reform the closing process and accompanying paperwork Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs (House, Senate, OCC, FDIC, CFPB) CBAI 2017 Federal Policy Priorities Regarding the implementation of regulatory initiatives - Consumer Financial Protection Bureaus (CFPB) proposed payday and vehicle title (small-dollar credit) lending rules The issue of too-big-to-fail banks and financial firms - protect our financial system, economy and taxpayers from future bailouts - The growing number of credible proposals to address TBTF and reduce the risks the mega banks poses to the financial system, economy and American taxpayers including those from: FDIC Vice Chairman Thomas Hoenig, Minneapolis Federal Reserve Chairman Neel Kashkari and Arthur Wilmarth - George Washington University Law School professor and a nationally recognized authority on bank regulation. These plans are in addition to a number of legislative proposals including a 21st century version of the original 1933 Glass-Steagall [separation of banking and commerce] Act. Taxation of credit unions and their expansion of powers - Outdated original business model, straying from their founding mission, ignoring field of membership or common bond requirement, now provide the same financial services as community banks, expansionist agenda, cheerleader regulator - National Credit Union Administration, justification for federal tax-exempt status, blatant discrimination against tax-paying community banks, eliminate subsidies or pay fair share of income taxes. Enhanced data, cyber and payment card security (data security) - Wide-scale data security breaches at national retail chain stores and other entities, far-reaching and costly incidents resulting in reissuing credit and debit cards at a considerable cost. Community banks defense against cyber security threats, their role in securing data and personal information as a matter of good business practice and to comply with legal and regulatory requirements. Data security principals include the cost of data breaches borne by that party that caused the breach, all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards, a national data security breach and notification standard should replace the current patchwork of state laws, and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations. Community banks reliance on third party service providers (core data processors and subcontractors of technology service providers for example), broadening the regulatory supervision of these service providers to ensure they comply with nondisclosure and confidentiality requirements similar to existing requirements for community banks. Mortgage lending and housing finance reform - Community banks strength of their reputation, incentive to make fair and reasonable loans, and do not need prescriptive regulations to compel them to do what is right for their customers Community bank loans held in portfolio receiving automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs), increase in the small servicer exemption, increase in HMDA reporting levels, a safe harbor from the newly implemented TRID, accommodations for community banks to provide greater flexibility in serving the needs of their customers and communities, (particularly in rural areas, and urges expanding the definition of underserved areas to include economically challenged areas), use of property evaluations completed by qualified bank staff in lieu of a residential property appraisal for any residential mortgage that a community bank originates and retains in its portfolio. Regarding the reform of the housing GSEs, the continued existence of an impartial secondary market for residential mortgages that is financially strong and reliable, some level of government involvement in the secondary market to ensure the continued flow of credit and market liquidity during periods of severe economic stress, reform that does not limit the full participation by community banks or disrupts the housing market, encouraging a return of private capital to reduce the reliance on government funding and help protect taxpayers from another bailout, sale of loans through an independent entity that does not compete with community banks, no appropriation of community bank customer data for the purpose of cross selling financial services, the Federal Home Loan Banks preserved as a community bank access point (but not the only access point) to the national secondary market, the pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed, the 30-year fixed-rate mortgage for creditworthy customers in all markets, no further consolidation of the housing finance system that would result in mega banks and financial firms dominating the market. Consumer Financial Protection Bureau Reform - The Consumer Financial Protection Bureau (CFPB) use of its statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, focus of regulation of financial products on the mega banks and financial firms and the unregulated shadow financial industry, community bank flexibility to meet the unique needs of its customers, burdening community banks with additional and unnecessary regulatory requirements that could prevent them from serving their communities, a one-size-fits-all approach to CFPB regulations, influencing the marketplace behavior by targeting of financial institutions, products, services, practices deemed to be undesirable or inappropriate, replacing single-Director governance with a five-member commission, prudential regulators participation with the CFPB in the rule-writing process, and the Financial Stability Oversight Council (FSOC) power to veto CFPB rules. (House, Senate, OCC, FDIC, CFPB) Legislation - H.R. 2954 - Home Mortgage Disclosure Adjustment Act (HMDA thresholds) (All Sections) (House, OCC, CFPB, FDIC) S. 1310 - Home Mortgage Disclosure Adjustment Act (HMDA thresholds) (All Sections) (Senate, OCC, CFPB, FDIC) H.R. 2133 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEARR Act of 2017) - (regulatory relief) (All Sections) (House, OCC, CFPB, FDIC) S. 1002 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEAR Relief Act of 2017) (regulatory relief) (All Sections) (Senate, OCC, CFPB, FDIC) H.R. 2890 - Housing Opportunity Mortgage Expansion Act (captive insurance company membership in the FHLBs) (All Sections) (House and Senate - companion legislation, OCC, CFPB, FDIC) S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections except those regarding prudential standards applicable solely to banks over $10 billion in assets (Section 401) and credit unions (Section 105) (Senate and House) H.R. 1 - The Tax Cuts and Jobs Act (Sections particularly concerning the individual rate, corporate rate, Subchapter S pass through rate, mortgage servicing assets (13221), business interest deduction, mortgage interest deduction, state and local taxes (SALT), estate taxes, corporate Alternative Minimum Taxes (AMT), non-qualified deferred compensation plans, and deductions for FDIC premiums) (House and Senate) H.R. 3971 - Community Institution Mortgage Relief Act of 2017 (All Sections) (House) Miscellaneous - Equifax data breach (House, Senate, CFPB, OCC, FDIC) Principals of Tax Relief and Reform (House, Senate, OCC, CFPB, FDIC) Principals of GSE Reform (House, Senate, OCC, CFPB, FDIC) Expansionist Agenda of Credit Unions and the Farm Credit System (House, Senate, OCC, CFPB, FDIC)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Access to Capital Restore the original intent of the Basel III rule Create a more accurate identification of systemic risk Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement Relieve community banks from excessive Securities and Exchange Commission rules Repeal the Collins Amendment for non-SIFIs Address minority bank capital challenges Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Mortgage Reform Create a safe harbor from onerous underwriting standards Establish relief from burdensome HMDA, escrow and appraisal requirements Preserve the ability for community banks to continue servicing mortgage loans Reform the closing process and accompanying paperwork Bank Oversight and Examination Strengthen accountability in bank exams and create a workable appeals process Reform bank oversight and examination to better target risk Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate, OCC, FDIC, CFPB) CBAI 2017 Federal Policy Priorities Meaningful regulatory relief, together with tiered regulation and supervision for community banks, as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity - See above. Regarding the implementation of regulatory initiatives - Special purpose fintech national bank charters by the OCC to financial technology companies Financial Accounting Standards Board (FASB) Current Expected Credit Loss Model (CECL) Consumer Financial Protection Bureaus (CFPB) proposed payday and vehicle title (small-dollar credit) lending rules De novo bank formation, the dual banking system, and charter choice The issue of too-big-to-fail banks and financial firms - protect our financial system, economy and taxpayers from future bailouts - Credible proposals to address TBTF and reduce the risks the mega banks poses to the financial system, economy and American taxpayers including those from: FDIC Vice Chairman Thomas Hoenig, Minneapolis Federal Reserve Chairman Neel Kashkari and Arthur Wilmarth - George Washington University Law School professor and a nationally recognized authority on bank regulation. These plans are in addition to a number of legislative proposals including a 21st century version of the original 1933 Glass-Steagall [separation of banking and commerce] Act. New Farm Bill and abolishing (or reigning-in) the Farm Credit System, crop insurance, USDA loan guarantee programs - volume caps and additional funding - Expansionist agenda of the Farm Credit System (FCS), the benefits of their Government Sponsored Enterprise (GSE) status, funding and tax advantages of the FCS, direct competition with community banks, cheerleader regulator - Farm Credit Administration (FCA), blatant discrimination against rural community banks, following its narrow historic mission of serving bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives, Joint House/Senate hearings, abolish or subject FCS to funding restrictions, taxation and rigorous oversight and regulation. Taxation of credit unions and their expansion of powers - Outdated original business model, straying from their founding mission, ignoring field of membership or common bond requirement, now provide the same financial services as community banks, expansionist agenda, cheerleader regulator - National Credit Union Administration, justification for federal tax-exempt status, blatant discrimination against tax-paying community banks, eliminate subsidies or pay fair share of income taxes. Enhanced data, cyber and payment card security (data security) - Wide-scale data security breaches at national retail chain stores and other entities, far-reaching and costly incidents resulting in reissuing credit and debit cards at a considerable cost. Community banks defense against cyber security threats, their role in securing data and personal information as a matter of good business practice and to comply with legal and regulatory requirements. Data security principals include the cost of data breaches borne by that party that caused the breach, all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards, a national data security breach and notification standard should replace the current patchwork of state laws, and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations. Community banks reliance on third party service providers (core data processors and subcontractors of technology service providers for example), broadening the regulatory supervision of these service providers to ensure they comply with nondisclosure and confidentiality requirements similar to existing requirements for community banks. Mortgage lending and housing finance reform - Community banks strength of their reputation, incentive to make fair and reasonable loans, and do not need prescriptive regulations to compel them to do what is right for their customers Community bank loans held in portfolio receiving automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs), increase in the small servicer exemption, increase in HMDA reporting levels, a safe harbor from the newly implemented TRID, accommodations for community banks to provide greater flexibility in serving the needs of their customers and communities, (particularly in rural areas, and urges expanding the definition of underserved areas to include economically challenged areas), use of property evaluations completed by qualified bank staff in lieu of a residential property appraisal for any residential mortgage that a community bank originates and retains in its portfolio. Regarding the reform of the housing GSEs, the continued existence of an impartial secondary market for residential mortgages that is financially strong and reliable, some level of government involvement in the secondary market to ensure the continued flow of credit and market liquidity during periods of severe economic stress, reform that does not limit the full participation by community banks or disrupts the housing market, encouraging a return of private capital to reduce the reliance on government funding and help protect taxpayers from another bailout, sale of loans through an independent entity that does not compete with community banks, no appropriation of community bank customer data for the purpose of cross selling financial services, the Federal Home Loan Banks preserved as a community bank access point (but not the only access point) to the national secondary market, the pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed, the 30-year fixed-rate mortgage for creditworthy customers in all markets, no further consolidation of the housing finance system that would result in mega banks and financial firms dominating the market. Consumer Financial Protection Bureau Reform - The Consumer Financial Protection Bureau (CFPB) use of its statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, focus of regulation of financial products on the mega banks and financial firms and the unregulated shadow financial industry, community bank flexibility to meet the unique needs of its customers, burdening community banks with additional and unnecessary regulatory requirements that could prevent them from serving their communities, a one-size-fits-all approach to CFPB regulations, influencing the marketplace behavior by targeting of financial institutions, products, services, practices deemed to be undesirable or inappropriate, replacing single-Director governance with a five-member commission, prudential regulators participation with the CFPB in the rule-writing process, and the Financial Stability Oversight Council (FSOC) power to veto CFPB rules. Maintain the Federal Home Loan Bank System - The regional structure, special functions and purposes of the FHLBs, the System remaining a financially sound, stable and reliable source of funding for its members, reliance upon it as the sole aggregator or securitizer of residential mortgages for community banks, the FHFA imposing an ongoing housing mission asset test on community financial institutions, rulemaking to restrict FHLB membership eligibility requirements. (House, Senate, OCC, FDIC, CFPB) Legislation - H.R. 2954 - Home Mortgage Disclosure Adjustment Act (HMDA thresholds) (All Sections) (House, OCC, FDIC, CFPB) S. 1310 - Home Mortgage Disclosure Adjustment Act (HMDA thresholds) (All Sections) (Senate, OCC, FDIC, CFPB) H.R. 2133 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEARR Act of 2017) - (regulatory relief) (All Sections) (House, OCC, FDIC, CFPB) S. 1002 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEAR Relief Act of 2017) (regulatory relief) (All Sections) (Senate, OCC, FDIC, CFPB) H.R. 2890 - Housing Opportunity Mortgage Expansion Act (captive insurance company membership in the FHLBs) (All Sections) (House and Senate - companion legislation, OCC, FDIC, CFPB) S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections except those regarding prudential standards applicable solely to banks over $10 billion in assets (Section 401) and credit unions (Section 105) (Senate and House) H.R. 1 - The Tax Cuts and Jobs Act (Sections particularly concerning the individual rate, corporate rate, Subchapter S pass through rate, mortgage servicing assets (13221), business interest deduction, mortgage interest deduction, state and local taxes (SALT), estate taxes, corporate Alternative Minimum Taxes (AMT), non-qualified deferred compensation plans, and deductions for FDIC premiums) (House and Senate) H.R. 3971 - Community Institution Mortgage Relief Act of 2017 (All Sections) (House) Comment Letters - Comment Letter - OCC, FDIC, Federal Reserve - Notice of Proposed Rulemaking - Simplification of Capital Rules Pursuant to EGRPRA: OCC Docket ID OCC-2017-0018, Federal Reserve Board Docket ID No. R-1576: RIN 7100 AE-74; FDIC RIN 3064-AE50 Action Alerts - Action Alert regarding Subchapter S (pass through rate) in tax reform legislation - H.R. 1, the Tax Cuts and Jobs Act (House and Senate) Second Action Alert regarding Subchapter S (pass through rate) in tax reform legislation - H.R. 1, the Tax Cuts and Jobs Act (House and Senate) Miscellaneous - Financial Accounting Standards Board (FASB) Current Expected Credit Loss (CECL) model (House) Equifax data breach (House, Senate, CFPB, OCC, FDIC) Principals of Tax Relief and Reform (House, Senate, OCC, CFPB, FDIC) Support for Agricultural and Rural America (House, Senate, OCC, CFPB, FDIC) Principals of GSE Reform (House, Senate, OCC, CFPB, FDIC) Expansionist Agenda of Credit Unions and the Farm Credit System (House, Senate, OCC, CFPB, FDIC) Brokered Deposits (FDIC) Exemption for community banks under the Dodd-Frank 1022(b)(3)(A) (Senate and CFPB)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Access to Capital Restore the original intent of the Basel III rule Create a more accurate identification of systemic risk Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement Relieve community banks from excessive Securities and Exchange Commission rules Repeal the Collins Amendment for non-SIFIs Address minority bank capital challenges Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Mortgage Reform Create a safe harbor from onerous underwriting standards Establish relief from burdensome HMDA, escrow and appraisal requirements Preserve the ability for community banks to continue servicing mortgage loans Reform the closing process and accompanying paperwork Bank Oversight and Examination Strengthen accountability in bank exams and create a workable appeals process Reform bank oversight and examination to better target risk Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate, OCC, FDIC, CFPB) CBAI 2017 Federal Policy Priorities Meaningful regulatory relief, together with tiered regulation and supervision for community banks, as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity - See above. Regarding the implementation of regulatory initiatives - Special purpose fintech national bank charters by the OCC to financial technology companies Financial Accounting Standards Board (FASB) Current Expected Credit Loss Model (CECL) Consumer Financial Protection Bureaus (CFPB) proposed payday and vehicle title (small-dollar credit) lending rules De novo bank formation, the dual banking system, and charter choice The issue of too-big-to-fail banks and financial firms - protect our financial system, economy and taxpayers from future bailouts - Credible proposals to address TBTF and reduce the risks the mega banks poses to the financial system, economy and American taxpayers including those from: FDIC Vice Chairman Thomas Hoenig, Minneapolis Federal Reserve Chairman Neel Kashkari and Arthur Wilmarth - George Washington University Law School professor and a nationally recognized authority on bank regulation. These plans are in addition to a number of legislative proposals including a 21st century version of the original 1933 Glass-Steagall [separation of banking and commerce] Act. New Farm Bill and abolishing (or reigning-in) the Farm Credit System, crop insurance, USDA loan guarantee programs - volume caps and additional funding - Expansionist agenda of the Farm Credit System (FCS), the benefits of their Government Sponsored Enterprise (GSE) status, funding and tax advantages of the FCS, direct competition with community banks, cheerleader regulator - Farm Credit Administration (FCA), blatant discrimination against rural community banks, following its narrow historic mission of serving bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives, Joint House/Senate hearings, abolish or subject FCS to funding restrictions, taxation and rigorous oversight and regulation. Taxation of credit unions and their expansion of powers - Outdated original business model, straying from their founding mission, ignoring field of membership or common bond requirement, now provide the same financial services as community banks, expansionist agenda, cheerleader regulator - National Credit Union Administration, justification for federal tax-exempt status, blatant discrimination against tax-paying community banks, eliminate subsidies or pay fair share of income taxes. Enhanced data, cyber and payment card security (data security) - Wide-scale data security breaches at national retail chain stores and other entities, far-reaching and costly incidents resulting in reissuing credit and debit cards at a considerable cost. Community banks defense against cyber security threats, their role in securing data and personal information as a matter of good business practice and to comply with legal and regulatory requirements. Data security principals include the cost of data breaches borne by that party that caused the breach, all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards, a national data security breach and notification standard should replace the current patchwork of state laws, and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations. Community banks reliance on third party service providers (core data processors and subcontractors of technology service providers for example), broadening the regulatory supervision of these service providers to ensure they comply with nondisclosure and confidentiality requirements similar to existing requirements for community banks. Mortgage lending and housing finance reform - Community banks strength of their reputation, incentive to make fair and reasonable loans, and do not need prescriptive regulations to compel them to do what is right for their customers Community bank loans held in portfolio receiving automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs), increase in the small servicer exemption, increase in HMDA reporting levels, a safe harbor from the newly implemented TRID, accommodations for community banks to provide greater flexibility in serving the needs of their customers and communities, (particularly in rural areas, and urges expanding the definition of underserved areas to include economically challenged areas), use of property evaluations completed by qualified bank staff in lieu of a residential property appraisal for any residential mortgage that a community bank originates and retains in its portfolio. Regarding the reform of the housing GSEs, the continued existence of an impartial secondary market for residential mortgages that is financially strong and reliable, some level of government involvement in the secondary market to ensure the continued flow of credit and market liquidity during periods of severe economic stress, reform that does not limit the full participation by community banks or disrupts the housing market, encouraging a return of private capital to reduce the reliance on government funding and help protect taxpayers from another bailout, sale of loans through an independent entity that does not compete with community banks, no appropriation of community bank customer data for the purpose of cross selling financial services, the Federal Home Loan Banks preserved as a community bank access point (but not the only access point) to the national secondary market, the pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed, the 30-year fixed-rate mortgage for creditworthy customers in all markets, no further consolidation of the housing finance system that would result in mega banks and financial firms dominating the market. Consumer Financial Protection Bureau Reform - The Consumer Financial Protection Bureau (CFPB) use of its statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, focus of regulation of financial products on the mega banks and financial firms and the unregulated shadow financial industry, community bank flexibility to meet the unique needs of its customers, burdening community banks with additional and unnecessary regulatory requirements that could prevent them from serving their communities, a one-size-fits-all approach to CFPB regulations, influencing the marketplace behavior by targeting of financial institutions, products, services, practices deemed to be undesirable or inappropriate, replacing single-Director governance with a five-member commission, prudential regulators participation with the CFPB in the rule-writing process, and the Financial Stability Oversight Council (FSOC) power to veto CFPB rules. Maintain the Federal Home Loan Bank System - The regional structure, special functions and purposes of the FHLBs, the System remaining a financially sound, stable and reliable source of funding for its members, reliance upon it as the sole aggregator or securitizer of residential mortgages for community banks, the FHFA imposing an ongoing housing mission asset test on community financial institutions, rulemaking to restrict FHLB membership eligibility requirements. (House, Senate, OCC, FDIC, CFPB) Legislation - H.R. 2954 - Home Mortgage Disclosure Adjustment Act (HMDA thresholds) (All Sections) (House, OCC, FDIC, CFPB) S. 1310 - Home Mortgage Disclosure Adjustment Act (HMDA thresholds) (All Sections) (Senate, OCC, FDIC, CFPB) H.R. 2133 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEARR Act of 2017) - (regulatory relief) (All Sections) (House, OCC, FDIC, CFPB) S. 1002 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEAR Relief Act of 2017) (regulatory relief) (All Sections) (Senate, OCC, FDIC, CFPB) H.R. 2890 - Housing Opportunity Mortgage Expansion Act (captive insurance company membership in the FHLBs) (All Sections) (House and Senate - companion legislation, OCC, FDIC, CFPB) S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections except those regarding prudential standards applicable solely to banks over $10 billion in assets (Section 401) and credit unions (Section 105) (Senate and House) H.R. 1 - The Tax Cuts and Jobs Act (Sections particularly concerning the individual rate, corporate rate, Subchapter S pass through rate, mortgage servicing assets (13221), business interest deduction, mortgage interest deduction, state and local taxes (SALT), estate taxes, corporate Alternative Minimum Taxes (AMT), non-qualified deferred compensation plans, and deductions for FDIC premiums) (House and Senate) H.R. 3971 - Community Institution Mortgage Relief Act of 2017 (All Sections) (House) Comment Letters - Comment Letter - OCC, FDIC, Federal Reserve - Notice of Proposed Rulemaking - Simplification of Capital Rules Pursuant to EGRPRA: OCC Docket ID OCC-2017-0018, Federal Reserve Board Docket ID No. R-1576: RIN 7100 AE-74; FDIC RIN 3064-AE50 Action Alerts - Action Alert regarding Subchapter S (pass through rate) in tax reform legislation - H.R. 1, the Tax Cuts and Jobs Act (House and Senate) Second Action Alert regarding Subchapter S (pass through rate) in tax reform legislation - H.R. 1, the Tax Cuts and Jobs Act (House and Senate) Miscellaneous - Financial Accounting Standards Board (FASB) Current Expected Credit Loss (CECL) model (House) Equifax data breach (House, Senate, CFPB, OCC, FDIC) Principals of Tax Relief and Reform (House, Senate, OCC, CFPB, FDIC) Support for Agricultural and Rural America (House, Senate, OCC, CFPB, FDIC) Principals of GSE Reform (House, Senate, OCC, CFPB, FDIC) Expansionist Agenda of Credit Unions and the Farm Credit System (House, Senate, OCC, CFPB, FDIC) Brokered Deposits (FDIC) Exemption for community banks under the Dodd-Frank 1022(b)(3)(A) (Senate and CFPB)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate, OCC, FDIC, CFPB) CBAI 2017 Federal Policy Priorities New Farm Bill and abolishing (or reigning-in) the Farm Credit System, crop insurance, USDA loan guarantee programs - volume caps and additional funding - Expansionist agenda of the Farm Credit System (FCS), the benefits of their Government Sponsored Enterprise (GSE) status, funding and tax advantages of the FCS, direct competition with community banks, cheerleader regulator - Farm Credit Administration (FCA), blatant discrimination against rural community banks, following its narrow historic mission of serving bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives, Joint House/Senate hearings, abolish or subject FCS to funding restrictions, taxation and rigorous oversight and regulation. Taxation of credit unions and oppose their expansion of powers - Outdated original business model, straying from their founding mission, ignoring field of membership or common bond requirement, now provide the same financial services as community banks, expansionist agenda, cheerleader regulator - National Credit Union Administration, justification for federal tax-exempt status, blatant discrimination against tax-paying community banks, eliminate subsidies or pay fair share of income taxes. (House, Senate, OCC, FDIC, CFPB) Legislation - H.R. 2133 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEARR Act of 2017) - (regulatory relief) (All Sections) (House, OCC, CFPB, FDIC) S. 1002 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEAR Relief Act of 2017) (regulatory relief) (All Sections) (Senate, OCC, CFPB, FDIC) H.R. 1 - The Tax Cuts and Jobs Act (Sections particularly concerning the individual rate, corporate rate, Subchapter S pass through rate, mortgage servicing assets (13221), business interest deduction, mortgage interest deduction, state and local taxes (SALT), estate taxes, corporate Alternative Minimum Taxes (AMT), non-qualified deferred compensation plans, and deductions for FDIC premiums) (House and Senate) Action Alerts - Action Alert regarding Subchapter S (pass through rate) in tax reform legislation - H.R. 1, the Tax Cuts and Jobs Act (House and Senate) Second Action Alert regarding Subchapter S (pass through rate) in tax reform legislation - H.R. 1, the Tax Cuts and Jobs Act (House and Senate) Miscellaneous - Principals of Tax Relief and Reform (House, Senate, OCC, CFPB, FDIC) Expansionist Agenda of Credit Unions and the Farm Credit System (House, Senate, OCC, CFPB, FDIC)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Mortgage Reform Create a safe harbor from onerous underwriting standards Establish relief from burdensome HMDA, escrow and appraisal requirements Preserve the ability for community banks to continue servicing mortgage loans Reform the closing process and accompanying paperwork Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs (House, OCC, FDIC, CFPB) CBAI 2017 Federal Policy Priorities Regarding the implementation of regulatory initiatives - Consumer Financial Protection Bureaus (CFPB) proposed payday and vehicle title (small-dollar credit) lending rules The issue of too-big-to-fail banks and financial firms - protect our financial system, economy and taxpayers from future bailouts - The growing number of credible proposals to address TBTF and reduce the risks the mega banks poses to the financial system, economy and American taxpayers including those from: FDIC Vice Chairman Thomas Hoenig, Minneapolis Federal Reserve Chairman Neel Kashkari and Arthur Wilmarth - George Washington University Law School professor and a nationally recognized authority on bank regulation. These plans are in addition to a number of legislative proposals including a 21st century version of the original 1933 Glass-Steagall [separation of banking and commerce] Act. Taxation of credit unions and their expansion of powers - Outdated original business model, straying from their founding mission, ignoring field of membership or common bond requirement, now provide the same financial services as community banks, expansionist agenda, cheerleader regulator - National Credit Union Administration, justification for federal tax-exempt status, blatant discrimination against tax-paying community banks, eliminate subsidies or pay fair share of income taxes. Enhanced data, cyber and payment card security (data security) - Wide-scale data security breaches at national retail chain stores and other entities, far-reaching and costly incidents resulting in reissuing credit and debit cards at a considerable cost. Community banks defense against cyber security threats, their role in securing data and personal information as a matter of good business practice and to comply with legal and regulatory requirements. Data security principals include the cost of data breaches borne by that party that caused the breach, all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards, a national data security breach and notification standard should replace the current patchwork of state laws, and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations. Community banks reliance on third party service providers (core data processors and subcontractors of technology service providers for example), broadening the regulatory supervision of these service providers to ensure they comply with nondisclosure and confidentiality requirements similar to existing requirements for community banks. Mortgage lending and housing finance reform - Community banks strength of their reputation, incentive to make fair and reasonable loans, and do not need prescriptive regulations to compel them to do what is right for their customers Community bank loans held in portfolio receiving automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs), increase in the small servicer exemption, increase in HMDA reporting levels, a safe harbor from the newly implemented TRID, accommodations for community banks to provide greater flexibility in serving the needs of their customers and communities, (particularly in rural areas, and urges expanding the definition of underserved areas to include economically challenged areas), use of property evaluations completed by qualified bank staff in lieu of a residential property appraisal for any residential mortgage that a community bank originates and retains in its portfolio. Regarding the reform of the housing GSEs, the continued existence of an impartial secondary market for residential mortgages that is financially strong and reliable, some level of government involvement in the secondary market to ensure the continued flow of credit and market liquidity during periods of severe economic stress, reform that does not limit the full participation by community banks or disrupts the housing market, encouraging a return of private capital to reduce the reliance on government funding and help protect taxpayers from another bailout, sale of loans through an independent entity that does not compete with community banks, no appropriation of community bank customer data for the purpose of cross selling financial services, the Federal Home Loan Banks preserved as a community bank access point (but not the only access point) to the national secondary market, the pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed, the 30-year fixed-rate mortgage for creditworthy customers in all markets, no further consolidation of the housing finance system that would result in mega banks and financial firms dominating the market. Consumer Financial Protection Bureau Reform - The Consumer Financial Protection Bureau (CFPB) use of its statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, focus of regulation of financial products on the mega banks and financial firms and the unregulated shadow financial industry, community bank flexibility to meet the unique needs of its customers, burdening community banks with additional and unnecessary regulatory requirements that could prevent them from serving their communities, a one-size-fits-all approach to CFPB regulations, influencing the marketplace behavior by targeting of financial institutions, products, services, practices deemed to be undesirable or inappropriate, replacing single-Director governance with a five-member commission, prudential regulators participation with the CFPB in the rule-writing process, and the Financial Stability Oversight Council (FSOC) power to veto CFPB rules. (House, OCC, FDIC, CFPB) Legislation - H.R. 2890 - Housing Opportunity Mortgage Expansion Act (captive insurance company membership in the FHLBs) (All Sections) (House, and Senate - companion legislation) H.R. 2133 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEARR Act of 2017) - (regulatory relief) (All Sections) (House) S. 1002 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEAR Relief Act of 2017) (regulatory relief) (All Sections) (Senate) H.R. 2954 - Home Mortgage Disclosure Adjustment Act (HMDA thresholds) (All Sections) (House) Comment Letters - Comment Letter - CFPB - Proposed Rule with Request for Public Comment - Home Mortgage Disclosure (Regulation C): Temporary Increase in Institutional and Transaction Coverage Thresholds for Open-End Lines of Credit: CFPB-2017-0021 and RIN 3170-AA76 Miscellaneous - S. J. Res. 47 - Arbitration Rule - Trade Industry Letter (Senate) Principals of Tax Relief and Reform (House, Senate, OCC, CFPB, FDIC) Principals of GSE Reform (House roundtable) Expansionist Agenda of Credit Unions and the Farm Credit System (House, Senate, OCC, CFPB, FDIC) Disparate Impact causes of action (House)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Access to Capital Restore the original intent of the Basel III rule Create a more accurate identification of systemic risk Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement Relieve community banks from excessive Securities and Exchange Commission rules Repeal the Collins Amendment for non-SIFIs Address minority bank capital challenges Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Mortgage Reform Create a safe harbor from onerous underwriting standards Establish relief from burdensome HMDA, escrow and appraisal requirements Preserve the ability for community banks to continue servicing mortgage loans Reform the closing process and accompanying paperwork Bank Oversight and Examination Strengthen accountability in bank exams and create a workable appeals process Reform bank oversight and examination to better target risk Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, OCC, FDIC, CFPB) CBAI 2017 Federal Policy Priorities Meaningful regulatory relief, together with tiered regulation and supervision for community banks, as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity - See above. Regarding the implementation of regulatory initiatives - Special purpose fintech national bank charters by the OCC to financial technology companies Financial Accounting Standards Board (FASB) Current Expected Credit Loss Model (CECL) Consumer Financial Protection Bureaus (CFPB) proposed payday and vehicle title (small-dollar credit) lending rules De novo bank formation, the dual banking system, and charter choice The issue of too-big-to-fail banks and financial firms - protect our financial system, economy and taxpayers from future bailouts - Credible proposals to address TBTF and reduce the risks the mega banks poses to the financial system, economy and American taxpayers including those from: FDIC Vice Chairman Thomas Hoenig, Minneapolis Federal Reserve Chairman Neel Kashkari and Arthur Wilmarth - George Washington University Law School professor and a nationally recognized authority on bank regulation. These plans are in addition to a number of legislative proposals including a 21st century version of the original 1933 Glass-Steagall [separation of banking and commerce] Act. New Farm Bill and abolishing (or reigning-in) the Farm Credit System, crop insurance, USDA loan guarantee programs - volume caps and additional funding - Expansionist agenda of the Farm Credit System (FCS), the benefits of their Government Sponsored Enterprise (GSE) status, funding and tax advantages of the FCS, direct competition with community banks, cheerleader regulator - Farm Credit Administration (FCA), blatant discrimination against rural community banks, following its narrow historic mission of serving bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives, Joint House/Senate hearings, abolish or subject FCS to funding restrictions, taxation and rigorous oversight and regulation. Taxation of credit unions and their expansion of powers - Outdated original business model, straying from their founding mission, ignoring field of membership or common bond requirement, now provide the same financial services as community banks, expansionist agenda, cheerleader regulator - National Credit Union Administration, justification for federal tax-exempt status, blatant discrimination against tax-paying community banks, eliminate subsidies or pay fair share of income taxes. Enhanced data, cyber and payment card security (data security) - Wide-scale data security breaches at national retail chain stores and other entities, far-reaching and costly incidents resulting in reissuing credit and debit cards at a considerable cost. Community banks defense against cyber security threats, their role in securing data and personal information as a matter of good business practice and to comply with legal and regulatory requirements. Data security principals include the cost of data breaches borne by that party that caused the breach, all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards, a national data security breach and notification standard should replace the current patchwork of state laws, and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations. Community banks reliance on third party service providers (core data processors and subcontractors of technology service providers for example), broadening the regulatory supervision of these service providers to ensure they comply with nondisclosure and confidentiality requirements similar to existing requirements for community banks. Mortgage lending and housing finance reform - Community banks strength of their reputation, incentive to make fair and reasonable loans, and do not need prescriptive regulations to compel them to do what is right for their customers Community bank loans held in portfolio receiving automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs), increase in the small servicer exemption, increase in HMDA reporting levels, a safe harbor from the newly implemented TRID, accommodations for community banks to provide greater flexibility in serving the needs of their customers and communities, (particularly in rural areas, and urges expanding the definition of underserved areas to include economically challenged areas), use of property evaluations completed by qualified bank staff in lieu of a residential property appraisal for any residential mortgage that a community bank originates and retains in its portfolio. Regarding the reform of the housing GSEs, the continued existence of an impartial secondary market for residential mortgages that is financially strong and reliable, some level of government involvement in the secondary market to ensure the continued flow of credit and market liquidity during periods of severe economic stress, reform that does not limit the full participation by community banks or disrupts the housing market, encouraging a return of private capital to reduce the reliance on government funding and help protect taxpayers from another bailout, sale of loans through an independent entity that does not compete with community banks, no appropriation of community bank customer data for the purpose of cross selling financial services, the Federal Home Loan Banks preserved as a community bank access point (but not the only access point) to the national secondary market, the pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed, the 30-year fixed-rate mortgage for creditworthy customers in all markets, no further consolidation of the housing finance system that would result in mega banks and financial firms dominating the market. Consumer Financial Protection Bureau Reform - The Consumer Financial Protection Bureau (CFPB) use of its statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, focus of regulation of financial products on the mega banks and financial firms and the unregulated shadow financial industry, community bank flexibility to meet the unique needs of its customers, burdening community banks with additional and unnecessary regulatory requirements that could prevent them from serving their communities, a one-size-fits-all approach to CFPB regulations, influencing the marketplace behavior by targeting of financial institutions, products, services, practices deemed to be undesirable or inappropriate, replacing single-Director governance with a five-member commission, prudential regulators participation with the CFPB in the rule-writing process, and the Financial Stability Oversight Council (FSOC) power to veto CFPB rules. Maintain the Federal Home Loan Bank System - The regional structure, special functions and purposes of the FHLBs, the System remaining a financially sound, stable and reliable source of funding for its members, reliance upon it as the sole aggregator or securitizer of residential mortgages for community banks, the FHFA imposing an ongoing housing mission asset test on community financial institutions, rulemaking to restrict FHLB membership eligibility requirements. (House, OCC, FDIC, CFPB) Legislation - H.R. 2890 - Housing Opportunity Mortgage Expansion Act (captive insurance company membership in the FHLBs) (All Sections) (House and Senate - companion legislation) H.R. 2133 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEARR Act of 2017) - (regulatory relief) (All Sections) (House) S. 1002 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEAR Relief Act of 2017) (regulatory relief) (All Sections) (Senate) S.1500 - - Keeping Capital Local for Underserved Communities Act of 2017 (reciprocal deposits as brokered deposits) (All sections) (Senate) H.R. 2403 - Keeping Capital Local for Underserved Communities Act of 2017 (reciprocal deposits as brokered deposits) (All sections) (House) H.R. 2954 - Home Mortgage Disclosure Adjustment Act (HMDA thresholds) (All Sections) (House) Comment Letters - Comment Letter - CFPB - Proposed Rule with Request for Public Comment - Home Mortgage Disclosure (Regulation C): Temporary Increase in Institutional and Transaction Coverage Thresholds for Open-End Lines of Credit: CFPB-2017-0021 and RIN 3170-AA76 Comment Letter - OCC, FDIC and Federal Reserve - Proposed Agency Information Collection Activities; Comment Request, FFIEC 031, FFIEC 041, and FFIEC 051 Comment Letter - CFPB - Request for Information Regarding Small Business Lending Market; Docket No. CFPB-2017-0011 Comment Letter - OCC - Notice Seeking Public Input on Volcker Rule - Docket ID OCC- 2017-0014 Miscellaneous - S. J. Res. 47 - Arbitration Rule - Trade Industry Letter (Senate) Principals of Tax Relief and Reform (House, Senate, OCC, CFPB, FDIC) Support for Agricultural and Rural America (House, Senate, OCC, CFPB, FDIC) Principals of new multi-year Farm Bill (House letter) Principals of GSE Reform (House roundtable) Expansionist Agenda of Credit Unions and the Farm Credit System (House, Senate, OCC, CFPB, FDIC) Disparate Impact causes of action (House)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Access to Capital Restore the original intent of the Basel III rule Create a more accurate identification of systemic risk Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement Relieve community banks from excessive Securities and Exchange Commission rules Repeal the Collins Amendment for non-SIFIs Address minority bank capital challenges Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, OCC, FDIC, CFPB) CBAI 2017 Federal Policy Priorities Regarding the implementation of regulatory initiatives - Special purpose fintech national bank charters by the OCC to financial technology companies Taxation of credit unions and their expansion of powers - Outdated original business model, straying from their founding mission, ignoring field of membership or common bond requirement, now provide the same financial services as community banks, expansionist agenda, cheerleader regulator - National Credit Union Administration, justification for federal tax-exempt status, blatant discrimination against tax-paying community banks, eliminate subsidies or pay fair share of income taxes. Enhanced data, cyber and payment card security (data security) - Wide-scale data security breaches at national retail chain stores and other entities, far-reaching and costly incidents resulting in reissuing credit and debit cards at a considerable cost. Community banks defense against cyber security threats, their role in securing data and personal information as a matter of good business practice and to comply with legal and regulatory requirements. Data security principals include the cost of data breaches borne by that party that caused the breach, all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards, a national data security breach and notification standard should replace the current patchwork of state laws, and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations. Community banks reliance on third party service providers (core data processors and subcontractors of technology service providers for example), broadening the regulatory supervision of these service providers to ensure they comply with nondisclosure and confidentiality requirements similar to existing requirements for community banks. (House, OCC, FDIC, CFPB) Legislation - H.R. 2133 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEARR Act of 2017) - (regulatory relief) (All Sections) (House) S. 1002 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEAR Relief Act of 2017) (regulatory relief) (All Sections) (Senate) Comment Letters - Comment Letter - CFPB - Request for Information Regarding Small Business Lending Market; Docket No. CFPB-2017-0011 Miscellaneous - Principals of Tax Relief and Reform (House, Senate, OCC, CFPB, FDIC) Support for Agricultural and Rural America (House, Senate, OCC, CFPB, FDIC) Principals of new multi-year Farm Bill (House letter) Expansionist Agenda of Credit Unions and the Farm Credit System (House, Senate, OCC, CFPB, FDIC)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, OCC, FDIC, CFPB) CBAI 2017 Federal Policy Priorities New Farm Bill and abolishing (or reigning-in) the Farm Credit System, crop insurance, USDA loan guarantee programs - volume caps and additional funding - Expansionist agenda of the Farm Credit System (FCS), the benefits of their Government Sponsored Enterprise (GSE) status, funding and tax advantages of the FCS, direct competition with community banks, cheerleader regulator - Farm Credit Administration (FCA), blatant discrimination against rural community banks, following its narrow historic mission of serving bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives, Joint House/Senate hearings, abolish or subject FCS to funding restrictions, taxation and rigorous oversight and regulation. Taxation of credit unions and oppose their expansion of powers - Outdated original business model, straying from their founding mission, ignoring field of membership or common bond requirement, now provide the same financial services as community banks, expansionist agenda, cheerleader regulator - National Credit Union Administration, justification for federal tax-exempt status, blatant discrimination against tax-paying community banks, eliminate subsidies or pay fair share of income taxes. (House, OCC, FDIC, CFPB) Legislation - H.R. 2133 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEARR Act of 2017) - (regulatory relief) (All Sections) (House) S. 1002 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEAR Relief Act of 2017) (regulatory relief) (All Sections) (Senate) Miscellaneous - Principals of Tax Relief and Reform (House, Senate, OCC, CFPB, FDIC) Expansionist Agenda of Credit Unions and the Farm Credit System (House, Senate, OCC, CFPB, FDIC)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, OCC, FDIC, CFPB) CBAI 2017 Federal Policy Priorities New Farm Bill and abolishing (or reigning-in) the Farm Credit System, crop insurance, USDA loan guarantee programs - volume caps and additional funding - Expansionist agenda of the Farm Credit System (FCS), the benefits of their Government Sponsored Enterprise (GSE) status, funding and tax advantages of the FCS, direct competition with community banks, cheerleader regulator - Farm Credit Administration (FCA), blatant discrimination against rural community banks, following its narrow historic mission of serving bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives, Joint House/Senate hearings, abolish or subject FCS to funding restrictions, taxation and rigorous oversight and regulation. Mortgage lending and housing finance reform - Community banks strength of their reputation, incentive to make fair and reasonable loans, and do not need prescriptive regulations to compel them to do what is right for their customers Community bank loans held in portfolio receiving automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs), increase in the small servicer exemption, increase in HMDA reporting levels, a safe harbor from the newly implemented TRID, accommodations for community banks to provide greater flexibility in serving the needs of their customers and communities, (particularly in rural areas, and urges expanding the definition of underserved areas to include economically challenged areas), use of property evaluations completed by qualified bank staff in lieu of a residential property appraisal for any residential mortgage that a community bank originates and retains in its portfolio. Regarding the reform of the housing GSEs, the continued existence of an impartial secondary market for residential mortgages that is financially strong and reliable, some level of government involvement in the secondary market to ensure the continued flow of credit and market liquidity during periods of severe economic stress, reform that does not limit the full participation by community banks or disrupts the housing market, encouraging a return of private capital to reduce the reliance on government funding and help protect taxpayers from another bailout, sale of loans through an independent entity that does not compete with community banks, no appropriation of community bank customer data for the purpose of cross selling financial services, the Federal Home Loan Banks preserved as a community bank access point (but not the only access point) to the national secondary market, the pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed, the 30-year fixed-rate mortgage for creditworthy customers in all markets, no further consolidation of the housing finance system that would result in mega banks and financial firms dominating the market. (House, OCC, FDIC, CFPB) Miscellaneous - Support for Agricultural and Rural America (House, Senate, OCC, CFPB, FDIC) Principals of new multi-year Farm Bill (House letter) Expansionist Agenda of Credit Unions and the Farm Credit System (House, Senate, OCC, CFPB, FDIC)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Access to Capital Restore the original intent of the Basel III rule Create a more accurate identification of systemic risk Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement Relieve community banks from excessive Securities and Exchange Commission rules Repeal the Collins Amendment for non-SIFIs Address minority bank capital challenges Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate) CBAI 2017 Federal Policy Priorities Regarding the implementation of regulatory initiatives - Special purpose fintech national bank charters by the OCC to financial technology companies Taxation of credit unions and their expansion of powers - Outdated original business model, straying from their founding mission, ignoring field of membership or common bond requirement, now provide the same financial services as community banks, expansionist agenda, cheerleader regulator - National Credit Union Administration, justification for federal tax-exempt status, blatant discrimination against tax-paying community banks, eliminate subsidies or pay fair share of income taxes. Enhanced data, cyber and payment card security (data security) - Wide-scale data security breaches at national retail chain stores and other entities, far-reaching and costly incidents resulting in reissuing credit and debit cards at a considerable cost. Community banks defense against cyber security threats, their role in securing data and personal information as a matter of good business practice and to comply with legal and regulatory requirements. Data security principals include the cost of data breaches borne by that party that caused the breach, all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards, a national data security breach and notification standard should replace the current patchwork of state laws, and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations. Community banks reliance on third party service providers (core data processors and subcontractors of technology service providers for example), broadening the regulatory supervision of these service providers to ensure they comply with nondisclosure and confidentiality requirements similar to existing requirements for community banks. (House, Senate) Legislation - H.R. 10 - Financial CHOICE Act (financial regulations) (All Sections but particularly Title V, debit interchange, repeal of 10% cap on deposits/liabilities) (House) H.R. 2133 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEARR Act of 2017) - (regulatory relief) (All Sections) (House) S. 1002 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEAR Relief Act of 2017) (regulatory relief) (All Sections) (Senate) Comment Letters - Comment Letter - OCC - Summary of Comments and Explanatory Statement: Special Purpose National Banking Charters for Financial Technology Companies, and Licensing Manual Statement for Evaluating Charter Applications From Financial Technology Companies Comment Letter - NCUA - Advanced Notice of Proposed Rulemaking for Supplemental Capital; Docket ID: NCUA-2017-0007; FR #2017-01713 Action Alerts - Action Alert - Regarding CLEAR Act - Urge Illinois congressional delegation to cosponsor the CLEAR Act. (H.R. 2133) Miscellaneous - OCC issuing special purpose national banking charters for financial Technology (fintech) companies (House and Senate) CFPB small business data collection (upcoming proposal) (House)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate) CBAI 2017 Federal Policy Priorities New Farm Bill and abolishing (or reigning-in) the Farm Credit System, crop insurance, USDA loan guarantee programs - volume caps and additional funding - Expansionist agenda of the Farm Credit System (FCS), the benefits of their Government Sponsored Enterprise (GSE) status, funding and tax advantages of the FCS, direct competition with community banks, cheerleader regulator - Farm Credit Administration (FCA), blatant discrimination against rural community banks, following its narrow historic mission of serving bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives, Joint House/Senate hearings, abolish or subject FCS to funding restrictions, taxation and rigorous oversight and regulation. Taxation of credit unions and oppose their expansion of powers - Outdated original business model, straying from their founding mission, ignoring field of membership or common bond requirement, now provide the same financial services as community banks, expansionist agenda, cheerleader regulator - National Credit Union Administration, justification for federal tax-exempt status, blatant discrimination against tax-paying community banks, eliminate subsidies or pay fair share of income taxes. (House and Senate) Legislation - H.R. 2133 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEARR Act of 2017) - (regulatory relief) (All Sections) (House) S. 1002 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEAR Relief Act of 2017) (regulatory relief) (All Sections) (Senate) Comment Letters - Comment Letter - NCUA - Advanced Notice of Proposed Rulemaking for Supplemental Capital; Docket ID: NCUA-2017-0007; FR #2017-01713 Action Alerts - Action Alert - Regarding NCUA alternative capital rules - Oppose credit union alternative capital rules Action Alert - Regarding CLEAR Act - Urge Illinois congressional delegation to cosponsor the CLEAR Act. (H.R. 2133)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate) CBAI 2017 Federal Policy Priorities New Farm Bill and abolishing (or reigning-in) the Farm Credit System, crop insurance, USDA loan guarantee programs - volume caps and additional funding - Expansionist agenda of the Farm Credit System (FCS), the benefits of their Government Sponsored Enterprise (GSE) status, funding and tax advantages of the FCS, direct competition with community banks, cheerleader regulator - Farm Credit Administration (FCA), blatant discrimination against rural community banks, following its narrow historic mission of serving bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives, Joint House/Senate hearings, abolish or subject FCS to funding restrictions, taxation and rigorous oversight and regulation. Mortgage lending and housing finance reform - Community banks strength of their reputation, incentive to make fair and reasonable loans, and do not need prescriptive regulations to compel them to do what is right for their customers Community bank loans held in portfolio receiving automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs), increase in the small servicer exemption, increase in HMDA reporting levels, a safe harbor from the newly implemented TRID, accommodations for community banks to provide greater flexibility in serving the needs of their customers and communities, (particularly in rural areas, and urges expanding the definition of underserved areas to include economically challenged areas), use of property evaluations completed by qualified bank staff in lieu of a residential property appraisal for any residential mortgage that a community bank originates and retains in its portfolio. Regarding the reform of the housing GSEs, the continued existence of an impartial secondary market for residential mortgages that is financially strong and reliable, some level of government involvement in the secondary market to ensure the continued flow of credit and market liquidity during periods of severe economic stress, reform that does not limit the full participation by community banks or disrupts the housing market, encouraging a return of private capital to reduce the reliance on government funding and help protect taxpayers from another bailout, sale of loans through an independent entity that does not compete with community banks, no appropriation of community bank customer data for the purpose of cross selling financial services, the Federal Home Loan Banks preserved as a community bank access point (but not the only access point) to the national secondary market, the pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed, the 30-year fixed-rate mortgage for creditworthy customers in all markets, no further consolidation of the housing finance system that would result in mega banks and financial firms dominating the market. (House, Senate) Comment Letters - Comment Letter - CFPB - Proposed Rule with Request for Comments - Home Mortgage Disclosure (Regulation C); CFPB-2017-0010 or RIN 3170-AA64

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Access to Capital Restore the original intent of the Basel III rule Create a more accurate identification of systemic risk Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement Relieve community banks from excessive Securities and Exchange Commission rules Repeal the Collins Amendment for non-SIFIs Address minority bank capital challenges Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Mortgage Reform Create a safe harbor from onerous underwriting standards Establish relief from burdensome HMDA, escrow and appraisal requirements Preserve the ability for community banks to continue servicing mortgage loans Reform the closing process and accompanying paperwork Bank Oversight and Examination Strengthen accountability in bank exams and create a workable appeals process Reform bank oversight and examination to better target risk Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate) CBAI 2017 Federal Policy Priorities Meaningful regulatory relief, together with tiered regulation and supervision for community banks, as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity - See above. Regarding the implementation of regulatory initiatives - Special purpose fintech national bank charters by the OCC to financial technology companies Financial Accounting Standards Board (FASB) Current Expected Credit Loss Model (CECL) Consumer Financial Protection Bureaus (CFPB) proposed payday and vehicle title (small-dollar credit) lending rules De novo bank formation, the dual banking system, and charter choice The issue of too-big-to-fail banks and financial firms - protect our financial system, economy and taxpayers from future bailouts - Credible proposals to address TBTF and reduce the risks the mega banks poses to the financial system, economy and American taxpayers including those from: FDIC Vice Chairman Thomas Hoenig, Minneapolis Federal Reserve Chairman Neel Kashkari and Arthur Wilmarth - George Washington University Law School professor and a nationally recognized authority on bank regulation. These plans are in addition to a number of legislative proposals including a 21st century version of the original 1933 Glass-Steagall [separation of banking and commerce] Act. New Farm Bill and abolishing (or reigning-in) the Farm Credit System, crop insurance, USDA loan guarantee programs - volume caps and additional funding - Expansionist agenda of the Farm Credit System (FCS), the benefits of their Government Sponsored Enterprise (GSE) status, funding and tax advantages of the FCS, direct competition with community banks, cheerleader regulator - Farm Credit Administration (FCA), blatant discrimination against rural community banks, following its narrow historic mission of serving bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives, Joint House/Senate hearings, abolish or subject FCS to funding restrictions, taxation and rigorous oversight and regulation. Taxation of credit unions and their expansion of powers - Outdated original business model, straying from their founding mission, ignoring field of membership or common bond requirement, now provide the same financial services as community banks, expansionist agenda, cheerleader regulator - National Credit Union Administration, justification for federal tax-exempt status, blatant discrimination against tax-paying community banks, eliminate subsidies or pay fair share of income taxes. Enhanced data, cyber and payment card security (data security) - Wide-scale data security breaches at national retail chain stores and other entities, far-reaching and costly incidents resulting in reissuing credit and debit cards at a considerable cost. Community banks defense against cyber security threats, their role in securing data and personal information as a matter of good business practice and to comply with legal and regulatory requirements. Data security principals include the cost of data breaches borne by that party that caused the breach, all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards, a national data security breach and notification standard should replace the current patchwork of state laws, and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations. Community banks reliance on third party service providers (core data processors and subcontractors of technology service providers for example), broadening the regulatory supervision of these service providers to ensure they comply with nondisclosure and confidentiality requirements similar to existing requirements for community banks. Mortgage lending and housing finance reform - Community banks strength of their reputation, incentive to make fair and reasonable loans, and do not need prescriptive regulations to compel them to do what is right for their customers Community bank loans held in portfolio receiving automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs), increase in the small servicer exemption, increase in HMDA reporting levels, a safe harbor from the newly implemented TRID, accommodations for community banks to provide greater flexibility in serving the needs of their customers and communities, (particularly in rural areas, and urges expanding the definition of underserved areas to include economically challenged areas), use of property evaluations completed by qualified bank staff in lieu of a residential property appraisal for any residential mortgage that a community bank originates and retains in its portfolio. Regarding the reform of the housing GSEs, the continued existence of an impartial secondary market for residential mortgages that is financially strong and reliable, some level of government involvement in the secondary market to ensure the continued flow of credit and market liquidity during periods of severe economic stress, reform that does not limit the full participation by community banks or disrupts the housing market, encouraging a return of private capital to reduce the reliance on government funding and help protect taxpayers from another bailout, sale of loans through an independent entity that does not compete with community banks, no appropriation of community bank customer data for the purpose of cross selling financial services, the Federal Home Loan Banks preserved as a community bank access point (but not the only access point) to the national secondary market, the pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed, the 30-year fixed-rate mortgage for creditworthy customers in all markets, no further consolidation of the housing finance system that would result in mega banks and financial firms dominating the market. Consumer Financial Protection Bureau Reform - The Consumer Financial Protection Bureau (CFPB) use of its statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, focus of regulation of financial products on the mega banks and financial firms and the unregulated shadow financial industry, community bank flexibility to meet the unique needs of its customers, burdening community banks with additional and unnecessary regulatory requirements that could prevent them from serving their communities, a one-size-fits-all approach to CFPB regulations, influencing the marketplace behavior by targeting of financial institutions, products, services, practices deemed to be undesirable or inappropriate, replacing single-Director governance with a five-member commission, prudential regulators participation with the CFPB in the rule-writing process, and the Financial Stability Oversight Council (FSOC) power to veto CFPB rules. Maintain the Federal Home Loan Bank System - The regional structure, special functions and purposes of the FHLBs, the System remaining a financially sound, stable and reliable source of funding for its members, reliance upon it as the sole aggregator or securitizer of residential mortgages for community banks, the FHFA imposing an ongoing housing mission asset test on community financial institutions, rulemaking to restrict FHLB membership eligibility requirements. (House, Senate) Legislation - H.R. 10 - Financial CHOICE Act (financial regulations) (All Sections but particularly Title V, debit interchange, repeal of 10% cap on deposits/liabilities) (House) H.R. 2890 - Housing Opportunity Mortgage Expansion Act (captive insurance company membership in the FHLBs) (All Sections) (House) H.R. 2133 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEARR Act of 2017) - (regulatory relief) (All Sections) (House) S. 1002 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEAR Relief Act of 2017) (regulatory relief) (All Sections) (Senate) Comment Letters - Comment Letter - OCC - Summary of Comments and Explanatory Statement: Special Purpose National Banking Charters for Financial Technology Companies, and Licensing Manual Statement for Evaluating Charter Applications From Financial Technology Companies Comment Letter - NCUA - Advanced Notice of Proposed Rulemaking for Supplemental Capital; Docket ID: NCUA-2017-0007; FR #2017-01713 Comment Letter - CFPB - Proposed Rule with Request for Comments - Home Mortgage Disclosure (Regulation C); CFPB-2017-0010 or RIN 3170-AA64 Action Alerts - Action Alert - Regarding NCUA alternative capital rules - Oppose credit union alternative capital rules Action Alert - Regarding CLEAR Act - Urge Illinois congressional delegation to cosponsor the CLEAR Act. (H.R. 2133) Miscellaneous - OCC issuing special purpose national banking charters for financial Technology (fintech) companies (House and Senate) CFPB small business data collection (upcoming proposal) (House)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Mortgage Reform Create a safe harbor from onerous underwriting standards Establish relief from burdensome HMDA, escrow and appraisal requirements Preserve the ability for community banks to continue servicing mortgage loans Reform the closing process and accompanying paperwork Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs (House, Senate) CBAI 2017 Federal Policy Priorities Regarding the implementation of regulatory initiatives - Consumer Financial Protection Bureaus (CFPB) proposed payday and vehicle title (small-dollar credit) lending rules The issue of too-big-to-fail banks and financial firms - protect our financial system, economy and taxpayers from future bailouts - The growing number of credible proposals to address TBTF and reduce the risks the mega banks poses to the financial system, economy and American taxpayers including those from: FDIC Vice Chairman Thomas Hoenig, Minneapolis Federal Reserve Chairman Neel Kashkari and Arthur Wilmarth - George Washington University Law School professor and a nationally recognized authority on bank regulation. These plans are in addition to a number of legislative proposals including a 21st century version of the original 1933 Glass-Steagall [separation of banking and commerce] Act. Taxation of credit unions and their expansion of powers - Outdated original business model, straying from their founding mission, ignoring field of membership or common bond requirement, now provide the same financial services as community banks, expansionist agenda, cheerleader regulator - National Credit Union Administration, justification for federal tax-exempt status, blatant discrimination against tax-paying community banks, eliminate subsidies or pay fair share of income taxes. Enhanced data, cyber and payment card security (data security) - Wide-scale data security breaches at national retail chain stores and other entities, far-reaching and costly incidents resulting in reissuing credit and debit cards at a considerable cost. Community banks defense against cyber security threats, their role in securing data and personal information as a matter of good business practice and to comply with legal and regulatory requirements. Data security principals include the cost of data breaches borne by that party that caused the breach, all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards, a national data security breach and notification standard should replace the current patchwork of state laws, and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations. Community banks reliance on third party service providers (core data processors and subcontractors of technology service providers for example), broadening the regulatory supervision of these service providers to ensure they comply with nondisclosure and confidentiality requirements similar to existing requirements for community banks. Mortgage lending and housing finance reform - Community banks strength of their reputation, incentive to make fair and reasonable loans, and do not need prescriptive regulations to compel them to do what is right for their customers Community bank loans held in portfolio receiving automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs), increase in the small servicer exemption, increase in HMDA reporting levels, a safe harbor from the newly implemented TRID, accommodations for community banks to provide greater flexibility in serving the needs of their customers and communities, (particularly in rural areas, and urges expanding the definition of underserved areas to include economically challenged areas), use of property evaluations completed by qualified bank staff in lieu of a residential property appraisal for any residential mortgage that a community bank originates and retains in its portfolio. Regarding the reform of the housing GSEs, the continued existence of an impartial secondary market for residential mortgages that is financially strong and reliable, some level of government involvement in the secondary market to ensure the continued flow of credit and market liquidity during periods of severe economic stress, reform that does not limit the full participation by community banks or disrupts the housing market, encouraging a return of private capital to reduce the reliance on government funding and help protect taxpayers from another bailout, sale of loans through an independent entity that does not compete with community banks, no appropriation of community bank customer data for the purpose of cross selling financial services, the Federal Home Loan Banks preserved as a community bank access point (but not the only access point) to the national secondary market, the pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed, the 30-year fixed-rate mortgage for creditworthy customers in all markets, no further consolidation of the housing finance system that would result in mega banks and financial firms dominating the market. Consumer Financial Protection Bureau Reform - The Consumer Financial Protection Bureau (CFPB) use of its statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, focus of regulation of financial products on the mega banks and financial firms and the unregulated shadow financial industry, community bank flexibility to meet the unique needs of its customers, burdening community banks with additional and unnecessary regulatory requirements that could prevent them from serving their communities, a one-size-fits-all approach to CFPB regulations, influencing the marketplace behavior by targeting of financial institutions, products, services, practices deemed to be undesirable or inappropriate, replacing single-Director governance with a five-member commission, prudential regulators participation with the CFPB in the rule-writing process, and the Financial Stability Oversight Council (FSOC) power to veto CFPB rules. (House, Senate) Legislation - H.R. 10 - Financial CHOICE Act (financial regulations) (All Sections but particularly Title V, debit interchange, repeal of 10% cap on deposits/liabilities) (House) H.R. 2890 - Housing Opportunity Mortgage Expansion Act (captive insurance company membership in the FHLBs) (All Sections) (House) H.R. 2133 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEARR Act of 2017) - (regulatory relief) (All Sections) (House) S. 1002 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEAR Relief Act of 2017) (regulatory relief) (All Sections) (Senate) Comment Letters - Comment Letter - NCUA - Advanced Notice of Proposed Rulemaking for Supplemental Capital; Docket ID: NCUA-2017-0007; FR #2017-01713 Comment Letter - CFPB - Proposed Rule with Request for Comments - Home Mortgage Disclosure (Regulation C); CFPB-2017-0010 or RIN 3170-AA64 Action Alerts - Action Alert - Regarding NCUA alternative capital rules - Oppose credit union alternative capital rules Action Alert - Regarding CLEAR Act - Urge Illinois congressional delegation to cosponsor the CLEAR Act. (H.R. 2133)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Access to Capital Restore the original intent of the Basel III rule Create a more accurate identification of systemic risk Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement Relieve community banks from excessive Securities and Exchange Commission rules Repeal the Collins Amendment for non-SIFIs Address minority bank capital challenges Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Mortgage Reform Create a safe harbor from onerous underwriting standards Establish relief from burdensome HMDA, escrow and appraisal requirements Preserve the ability for community banks to continue servicing mortgage loans Reform the closing process and accompanying paperwork Bank Oversight and Examination Strengthen accountability in bank exams and create a workable appeals process Reform bank oversight and examination to better target risk Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate, Federal Reserve Board, FDIC, OCC, CFPB) Credit union and Farm Credit System taxation and expanded power including increase in percentage of asset cap on member business lending, access to investor capital to fund growth, and an expansion of credit union membership (House, Senate, Federal Reserve Board, FDIC, OCC, CFPB) Legislation - H.R. 389 - Credit Union Residential Loan Parity Act (Member Business Lending) (All sections) (House) Comment Letters - Comment Letter - FDIC - Request for Comments on Federal Deposit Insurance Corporation publication Applying for Deposit Insurance - A Handbook for Organizers of De Novo Institutions Comment letter - OCC - Office of the Comptroller of the Currency white paper titled Exploring Special Purpose National Bank Charters for Fintech Companies Miscellaneous - Americans with Disabilities (ADA) website trollers (House) Status of Wells Fargos examination results from 2012 Community Reinvestment Act (CRA) examination (House, Senate, Federal Reserve Board, FDIC, OCC, CFPB) Debit Interchange (House) FDIC approving applications for deposit insurance for de novo banks (House, Senate, Federal Reserve Board, FDIC, OCC, CFPB) OCC issuing Special Purpose National Bank (SPNB) charters for fintech companies (House, Senate, Federal Reserve Board, FDIC, OCC, CFPB)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate, Federal Reserve Board, FDIC, OCC, CFPB) Credit union and Farm Credit System taxation and expanded power including increase in percentage of asset cap on member business lending, access to investor capital to fund growth, and an expansion of credit union membership (House, Senate, Federal Reserve Board, FDIC, OCC, CFPB)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate, Federal Reserve Board, FDIC, OCC, CFPB) Credit union and Farm Credit System taxation and expanded power including increase in percentage of asset cap on member business lending, access to investor capital to fund growth, and an expansion of credit union membership (House, Senate, Federal Reserve Board, FDIC, OCC, CFPB) Legislation - H.R. 389 - Credit Union Residential Loan Parity Act (Member Business Lending) (All sections) (House)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Access to Capital Restore the original intent of the Basel III rule Create a more accurate identification of systemic risk Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement Relieve community banks from excessive Securities and Exchange Commission rules Repeal the Collins Amendment for non-SIFIs Address minority bank capital challenges Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate, Federal Reserve Board, FDIC, OCC, CFPB) Legislation - H.R. 389 - Credit Union Residential Loan Parity Act (Member Business Lending) (All sections) (House) Comment Letter - OCC - Office of the Comptroller of the Currency white paper titled Exploring Special Purpose National Bank Charters for Fintech Companies Miscellaneous - Americans with Disabilities (ADA) website trollers (House) OCC issuing Special Purpose National Bank (SPNB) charters for fintech companies (House, Senate, Federal Reserve Board, FDIC, OCC, CFPB)

Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Mortgage Reform Create a safe harbor from onerous underwriting standards Establish relief from burdensome HMDA, escrow and appraisal requirements Preserve the ability for community banks to continue servicing mortgage loans Reform the closing process and accompanying paperwork Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs (House, Senate, Federal Reserve Board, FDIC, OCC, CFPB) Credit union and Farm Credit System taxation and expanded power including increase in percentage of asset cap on member business lending, access to investor capital to fund growth, and an expansion of credit union membership (House, Senate, Federal Reserve Board, FDIC, OCC, CFPB) Legislation - H.R. 389 - Credit Union Residential Loan Parity Act (Member Business Lending) (All sections) (House) Miscellaneous - Americans with Disabilities (ADA) website trollers Status of Wells Fargos examination results from 2012 Community Reinvestment Act (CRA) examination (House, Senate, Federal Reserve Board, FDIC, OCC, CFPB) Debit Interchange (House)

Community Bankers Association of Illinois (CBAI) 2016 Federal Policy Priorities (House and Senate, OCC) Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by TBTFs during the financial crisis - different/modest risks posed by community banks - regulations reflecting those differences - regulatory burden on community banks - one-size-fits-all approach - disproportionate burden of banking laws and regulations on community banks Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks - unlevel playing field - a significant competitive disadvantage for community banks Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies Address excessive, redundant and costly regulations - regulatory accountability - community banks dedicating resources to promoting economic growth - steady increase in regulations over many decades - regulatory threats to community banks and their communities The Plan for Prosperity: Basel III original intent. accurately identify Systemic Risk additional capital for small holding companies - modernizing the Federal Reserves Policy Statement relief from Securities and Exchange Commission (SEC) rules robust housing market - reform mortgage lending community bank mortgage servicing accountability in bank exams - providing a workable appeals process bank oversight and examinations - better target risk risk targeting in the Volker Rule consumer regulation and inclusive and accountable CFPB governance arbitrary disparate impact fair lending causes of action viability of mutual banks - new charter and capital options rigorous and quantitative cost-benefit analysis - justify new rules red tape in small business lending - eliminating burdensome data collection credit for low and moderate income customers and American agriculture subchapter S corporation constraints Limited Liability Corporation (LLC) option for community banks Bank Qualified (BQ) bond issuer limitations five-year loss carryback to support lending during economic downturns. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation distinguishing and appropriately regulating community banks. Data, Cyber and Payment Card Security (Data Security) Wide-scale data security breaches at national retail chain stores and other entities - community banks reissuing credit and debit cards at a significant cost - community banks on the frontline of defending against cyber security threats and strong guardians of the security and confidentiality of customer information - central to maintaining public trust and the key to long-term customer retention Core data security principals - cost of data breaches borne by that party that caused the breach - all participants in the payment system (including merchants) should be subject to Gramm-Leach-Bliley Act-like data security standards - a national data security breach and notification standard should replace the current patchwork of state laws - and any new data security standards should ensure that community banks are not burdened with having to implement and comply with new regulations to achieve the same superior results they currently attain - community banks reliance on third party service providers - delicate balance between securing/sharing appropriate customer information Mortgage Lending and Housing Finance Reform Imprudent mortgage lendings contribution to the mortgage meltdown and the financial crisis - community banks common sense relationship lending - no need for prescriptive regulations to compel doing what is right for their customers - not negatively impacting responsible community bank loan products to meet diverse needs of their customers including borrowers with special needs and circumstances, first-time homebuyers, borrowers in rural and underserved areas, and low-to-moderate income borrowers - recognize differences between the non-traditional lending practiced by community banks and the predatory lending practices of others All community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas, receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs) - an increase in the small servicer exemption, an increase in the HMDA reporting levels - a formalized safe harbor during the TRID implementation period - broad special accommodations for community banks to provide flexibility in serving the needs of their customers and communities, particularly in rural areas - and expand definition of underserved areas to include economically challenged areas Untenable long-term position of government sponsored entities (GSEs) Fannie Mae (Fannie) and Freddie Mac (Freddie) in conservatorship by the United States Treasury run by the Federal Housing Finance Agency (FHFA). In reforming to the housing GSEs, the need for the continued existence of an impartial secondary market for residential mortgages for community banks which is financially strong and reliable - the need for some level of government involvement in the secondary market to ensure the continued flow of credit and market liquidity during periods of severe economic stress - no limit in full participation by community banks or disruption in the housing market - the return of private capital to reduce the reliance on government funding - protection of taxpayers from another bailout. Community bank sale of loans through an independent entity - not competing with community banks - no appropriation of community bank customer data for the purpose of cross selling financial services - the Federal Home Loan Banks preserved as a community bank access point (but not the only access point) to the national secondary market - the pricing of the governmental guaranty being fair and equal to all participants regardless of volume of loans guaranteed - no further consolidation of the housing finance system that would result in mega banks and financial firms dominating the market. Consumer Financial Protection Bureau Reform Consumer Financial Protection Bureau (CFPB) use of its statutory authority under the Dodd-Frank Act to exempt community banks or any products or services from the rules it writes - use of this authority to ensure community banks can continue to provide alternatives to large banks and non-banks for consumers seeking responsible financial service providers CFPB providing community banks with flexibility to meet unique needs of customers and not burden community banks with additional and unnecessary regulatory requirements to prevent them from serving their communities - no one-size-fits-all approach to CFPB regulations which harms community banks in meeting the unique needs of its local customers and communities - Community banks enduring any additional consumer regulatory burden on top of the existing burden they already face Single-Director governance of the CFPB vs. a five-member commission - residential regulators participate with the CFPB in the rule-writing process - Financial Stability Oversight Council (FSOC) power to veto CFPB rules under a practical and realistic standard - a broad definition of firms that grant credit being subject to the CFPB rules, and their supervision and examination Focus of any enhanced regulation of financial products on TBTF banks and financial firms and the unregulated shadow financial industry - efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products - holding all of the other financial service providers up to the existing high standards for compliance with consumer laws, rules and regulations as currently attained by community banks Excessive Intervention in Monetary Policy Sustained record-low zero interest rate policy (ZIRP) engineered and implemented by the Federal Reserve System - disproportionally impact on community banks, senior citizens and savers - a significant drag on the earnings of community banks - THBF banks with non-traditional banking business lines derive a much lower percentage of their earnings from net interest margins and are not as negatively impacted - limits to what Fed monetary policy can accomplish considering major offsetting negative effects on community banks, senior citizens, and savers Legislation - H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate, OCC) H.R. 1210 and S. 2995 - Portfolio Lending and Mortgage Access Act (automatic Qualified Mortgage (QM) protection for community bank mortgages held in portfolio) (All sections) (House and Senate, OCC) H.R. 4993 - Homeowners Information Privacy Protection Act (study privacy implications of new HMDA data fields) (All sections) (House and Senate, OCC) H.R. 4997 and S. 3215 - Home Mortgage Disclosure Adjustment Act (HMDA reporting relief for low volume mortgage lenders) (All sections) (House and Senate, OCC) H.R. 4099 - Consumer Financial Protection Bureau Examination and Reporting Threshold Act (increase the CFPBs examination, enforcement and reporting threshold) (All sections) (House and Senate, OCC) S. 1484 - Financial Regulatory Improvement Act and H.R. 5983 - Financial CHOICE Act - (both contain various community bank regulatory relief measures) (Title 1 in S. 1484) (All sections in H.R. 5983) (House and Senate, OCC) Comment Letters - Comment Letter - CFPB - Proposed Rule with Request for Public Comment - Payday, Vehicle Title, and Certain High-Cost Installment Loans: Docket No. CFPB-2016-0025 Action Alerts - Action Alert - Regarding Payday Lending Rules - Urge CFPB to exempt community banks Action Alert - Regarding Lame Duck session - Urge Illinois House and Senate members to pass regulatory relief measures Miscellaneous - Trade Association Industry Letter regarding enacting meaningful regulatory relief measures in the Lame Duck (All sections all bills except where noted) (House and Senate) - The CLEAR Relief Act (S. 812) includes automatic qualified mortgage (QM) status for community bank mortgages held in portfolio. The Home Mortgage Disclosure Adjustment Act (H.R. 4997/S. 3215) provides critical relief for low volume mortgage lenders without materially impacting the mortgage data available to the CFPB or impairing the purpose of the HMDA statute. The Financial Regulatory Improvement Act (S. 1484): Title I of S. 1484 includes provisions to promote community bank mortgage lending, including QM status for mortgages held in portfolio; create an exam cycle commensurate with the risk posed by community banks; bring more accountability to exams by the creation of an Ombudsman; and exempt community banks from a Volcker Rule.

Community Bankers Association of Illinois (CBAI) 2016 Federal Policy Priorities (House and Senate, OCC) Too-Big-To-Fail Banks and Financial Firms, Our Financial System, Economy, and American Taxpayers - Future Bailouts Reforming the financial system to reduce the possibility, probability, and severity of a future financial crisis - the perception and reality of too-big-to-fail (TBTF) - taxpayer bailouts of mega banks and financial firms - downsize TBTFs Growth, complexity, and interconnection of the TBTF banks - candidates for future bailouts - falling number of community banks representing less than one-fifth of banking professions assets TBTF banks and the mortgage meltdown and financial crisis - protection from massive financial destruction - taxpayer outrage at TBTFs - violations of the law (often criminal) and billions of dollars in fines, settlements and deferred prosecution agreements (conditional amnesty) TBTF effective management, supervision, discipline, and resolution - multi-trillion dollar financial assistance - rightful failure - little assistance for community banks - 500 subsequent failures and devastation U.S. Attorney General Eric Holder admission of a two-tiered system of justice, one for TBTF banks another for everyone else - board resolutions, MOUs, C&Ds, consent orders, monetary penalties, barring individuals from banking, criminal prosecution for community bank, directors, and officers - evidence of a double standard Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank) in Title II - end TBTF bailouts - Wall Street TBTF "single point of entry" (SPOE) plan for resolving failed Systemically Important Financial Institutions (SIFIs) - ensuring future bailouts for SIFIs imposing costs of bailouts on ordinary investors and taxpayers. SIFIs special long-term bonds - conversion to equity when a SIFI fails - sale of bonds to non-systemic investors - ordinary investors primary losers upon conversion into equity - insufficient to recapitalize a failed SIFI, the FDIC borrowing needed funds from the Treasury Department through the Orderly Liquidation Fund (OLF) - OLF current zero balance - backstopped by American taxpayers. Consideration of alternate resolution plans of Arthur Wilmarth, George Washington University Law School - TBTF internalize systemic risks - reduction in size and complexity - prohibition from selling special long-term bonds to ordinary individuals - SIFIs pay risk-adjusted insurance-type premiums to prefund the OLF at a level of $300 billion or more - incentive compensation rule to require SIFIs to pay at least half of total compensation to senior executives and other key employees in the form of contingent convertible bonds - expose insiders to immediate losses if SIFI fail during employment or during post-employment holding period Financial Accounting Standards Board (FASB) Current Expected Credit Loss (CECL) Model Financial Accounting Standards Board (FASB) proposed Current Expected Credit Loss (CECL) model - implications for community banks - prepare financial institutions for a future crisis - use of forward looking information in calculating loan loss reserves The current Incurred Loss model vs. CECL - estimated day one loss and adjust estimated losses continually throughout the life of each loan - pure speculation - CECL models extensive operating system changes and cash flow modeling capabilities - cost and regulatory burden - added reserves - lower future profits, reduce capital levels, decrease community bank lending Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by TBTFs during the financial crisis - different/modest risks posed by community banks - regulations reflecting those differences - regulatory burden on community banks - one-size-fits-all approach - disproportionate burden of banking laws and regulations on community banks Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks - unlevel playing field - a significant competitive disadvantage for community banks Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies Address excessive, redundant and costly regulations - regulatory accountability - community banks dedicating resources to promoting economic growth - steady increase in regulations over many decades - regulatory threats to community banks and their communities. The Plan for Prosperity: Basel III original intent. accurately identify Systemic Risk additional capital for small holding companies - modernizing the Federal Reserves Policy Statement relief from Securities and Exchange Commission (SEC) rules robust housing market - reform mortgage lending community bank mortgage servicing accountability in bank exams - providing a workable appeals process bank oversight and examinations - better target risk risk targeting in the Volker Rule consumer regulation and inclusive and accountable CFPB governance arbitrary disparate impact fair lending causes of action viability of mutual banks - new charter and capital options rigorous and quantitative cost-benefit analysis - justify new rules red tape in small business lending - eliminating burdensome data collection credit for low and moderate income customers and American agriculture subchapter S corporation constraints Limited Liability Corporation (LLC) option for community banks Bank Qualified (BQ) bond issuer limitations five-year loss carryback to support lending during economic downturns. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation distinguishing and appropriately regulating community banks. Credit Union Taxation and Expansion of Powers - Credit unions distinguishable from community banks - grown to control a significant share of the banking services market - outdated original business model - straying from founding purpose of serving individuals of modest means and with a common bond - same financial services as community banks - justification for federal tax-exempt status in exchange for serving their original mission - credit unions paying their fair share of income taxes - credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district - tax subsidy and level the playing field between credit unions and tax-paying community banks Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L) - the exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks] Credit union expansion of commercial lending powers - increasing the percentage of cap on member business lending (MBL) - loan growth at the expense of tax-paying community banks - fundamental altering the exclusive member-focused character of credit unions - condition for their original tax exemption Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts - the same Call Report filing requirements for credit unions as those imposed on community banks Support and cooperation of NCUA the cheerleader regulator of credit unions - expansion of membership proposal - weaken the common bond requirement - disregarding Congressional limits - end around Congress. Farm Credit System (FCS) - Expansionist agenda of the Farm Credit System (FCS) - the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status - tax advantages - unfair competitive advantage - follow narrow historic mission - abolish or be subject to taxation and oversight and regulation Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives Support and cooperation of cheerleader regulator of FCS lenders -Farm Credit Administration (FCA) - straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities - FCS significant systemic and taxpayer bail-out risks FCS (the only GSE) in active competition with community banks - public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks) Funding and tax benefit impact on community banks - not following its narrow historical mission - follow narrow mission or abolish FCSystem - abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks Data, Cyber and Payment Card Security (Data Security) Wide-scale data security breaches at national retail chain stores and other entities - community banks reissuing credit and debit cards at a significant cost - community banks on the frontline of defending against cyber security threats and strong guardians of the security and confidentiality of customer information - central to maintaining public trust and the key to long-term customer retention Core data security principals - cost of data breaches borne by that party that caused the breach - all participants in the payment system (including merchants) should be subject to Gramm-Leach-Bliley Act-like data security standards - a national data security breach and notification standard should replace the current patchwork of state laws - and any new data security standards should ensure that community banks are not burdened with having to implement and comply with new regulations to achieve the same superior results they currently attain - community banks reliance on third party service providers - delicate balance between securing/sharing appropriate customer information Mortgage Lending and Housing Finance Reform Imprudent mortgage lendings contribution to the mortgage meltdown and the financial crisis - community banks common sense relationship lending - no need for prescriptive regulations to compel doing what is right for their customers - not negatively impacting responsible community bank loan products to meet diverse needs of their customers including borrowers with special needs and circumstances, first-time homebuyers, borrowers in rural and underserved areas, and low-to-moderate income borrowers - recognize differences between the non-traditional lending practiced by community banks and the predatory lending practices of others All community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas, receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs) - an increase in the small servicer exemption, an increase in the HMDA reporting levels - a formalized safe harbor during the TRID implementation period - broad special accommodations for community banks to provide flexibility in serving the needs of their customers and communities, particularly in rural areas - and expand definition of underserved areas to include economically challenged areas Untenable long-term position of government sponsored entities (GSEs) Fannie Mae (Fannie) and Freddie Mac (Freddie) in conservatorship by the United States Treasury run by the Federal Housing Finance Agency (FHFA). In reforming to the housing GSEs, the need for the continued existence of an impartial secondary market for residential mortgages for community banks which is financially strong and reliable - the need for some level of government involvement in the secondary market to ensure the continued flow of credit and market liquidity during periods of severe economic stress - no limit in full participation by community banks or disruption in the housing market - the return of private capital to reduce the reliance on government funding - protection of taxpayers from another bailout. Community bank sale of loans through an independent entity - not competing with community banks - no appropriation of community bank customer data for the purpose of cross selling financial services - the Federal Home Loan Banks preserved as a community bank access point (but not the only access point) to the national secondary market - the pricing of the governmental guaranty being fair and equal to all participants regardless of volume of loans guaranteed - no further consolidation of the housing finance system that would result in mega banks and financial firms dominating the market. Consumer Financial Protection Bureau Reform Consumer Financial Protection Bureau (CFPB) use of its statutory authority under the Dodd-Frank Act to exempt community banks or any products or services from the rules it writes - use of this authority to ensure community banks can continue to provide alternatives to large banks and non-banks for consumers seeking responsible financial service providers CFPB providing community banks with flexibility to meet unique needs of customers and not burden community banks with additional and unnecessary regulatory requirements to prevent them from serving their communities - no one-size-fits-all approach to CFPB regulations which harms community banks in meeting the unique needs of its local customers and communities - Community banks enduring any additional consumer regulatory burden on top of the existing burden they already face Single-Director governance of the CFPB vs. a five-member commission - residential regulators participate with the CFPB in the rule-writing process - Financial Stability Oversight Council (FSOC) power to veto CFPB rules under a practical and realistic standard - a broad definition of firms that grant credit being subject to the CFPB rules, and their supervision and examination Focus of any enhanced regulation of financial products on TBTF banks and financial firms and the unregulated shadow financial industry - efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products - holding all of the other financial service providers up to the existing high standards for compliance with consumer laws, rules and regulations as currently attained by community banks De Novo Community Bank Formation and the Dual Banking System/Charter Choice Newly chartered (de novo) community banks importance in maintaining a strong, growing, evolving and vibrant banking profession - FDICs inhibiting de novo community bank formation during the financial crisis, FDICs indication of a change in policy direction by rescinding its Financial Institution Letter (FIL) 50-2009, Enhanced Supervisory Procedures for Newly Insured FDIC-Supervised Depository Institutions The importance of the dual banking system where chartering and supervision is divided between the federal government and the states - community banks choice of charters that best fits their business model - multi-agency (state and federal) regulators and charter choice providing necessary checks and balances on the power of the regulators, as well as improved rulemaking, the benefit of each agencies expertise and experience is brought to bear on complex and controversial issues Federal Home Loan Bank System Federal Home Loan Banks (FHLBs) strong partnership with community banks - providing short-term liquidity, long-term funding and other financial products that serve the needs of all member-owners - providing lendable funds for the local communities - regional structure, special functions and purposes of the FHLBs recognized and maintained by the Federal Housing Finance Agency (FHFA). FHFAs proposed rulemaking to revise FHLB membership eligibility requirements - negative impact on the FHLB System and its members - precedent set to terminate through rulemaking FHLB membership and the threat to revisit the broader membership issue in the future - contrary to the will of Congress FHLB System position as a healthy, stable and reliable source of funding for its members - not as the sole aggregator or securitizer of residential mortgages for community banks - FHFAs imposition of an ongoing housing mission asset test on community financial institutions Excessive Intervention in Monetary Policy Sustained record-low zero interest rate policy (ZIRP) engineered and implemented by the Federal Reserve System - disproportionally impact on community banks, senior citizens and savers - a significant drag on the earnings of community banks - THBF banks with non-traditional banking business lines derive a much lower percentage of their earnings from net interest margins and are not as negatively impacted - limits to what Fed monetary policy can accomplish considering major offsetting negative effects on community banks, senior citizens, and savers Legislation - H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate, OCC) H.R. 4500 and S. 927 - CLEAR Relief Act Plus Act (Call report regulatory relief for community banks) (All sections) (House and Senate, OCC) H.R.1523 and S. 1816 - Community Bank Access to Capital Act (exempt banks with assets of $50 billion or less from the Basel III regulatory capital rule, and provide an exemption from internal control attestation requirements for community banks with assets of less than $1 billion) (All sections) (House and Senate, OCC) H.R. 1210 and S. 2995 - Portfolio Lending and Mortgage Access Act (automatic Qualified Mortgage (QM) protection for community bank mortgages held in portfolio) (All sections) (House and Senate, OCC) H.R. 4993 - Homeowners Information Privacy Protection Act (study privacy implications of new HMDA data fields) (All sections) (House and Senate, OCC) H.R. 4997 and S. 3215 - Home Mortgage Disclosure Adjustment Act (HMDA reporting relief for low volume mortgage lenders) (All sections) (House and Senate, OCC) H.R. 4950 - Small Financial Institution Advisory Committee Act of 2016 (creates a Treasury Department community bank advisory committee) (All sections) (House and Senate, OCC) H.R. 5733 - Beginning Farmer and Rancher Guaranteed Loan Modernization Act (modifies limits applicable to qualified conservation loan guarantees) (All sections) (House and Senate, OCC) H.R. 4116/ S. 3373 (allows reciprocal deposits to serve as a stable source of funding to support community bank lending by ensuring that reciprocal deposits are not treated by the FDIC as brokered deposits.) (All sections) (House and Senate, OCC) H.R. 1766 - Right to Lend Act (repeals new small business loan data collection requirement) (All sections) (House and Senate, OCC) H.R. 5754 and S. 3181 - S Corporation Modernization Act (creates an additional source of capital for Subchapter S community banks by allowing them to accept IRA investments) (All sections) (House and Senate, OCC) H.R. 6100 and S. 3436 - (would block a Treasury and IRS proposal to effectively end estate-planning techniques commonly used to transfer community banks and other family-owned businesses to the next generation) (All Sections) (House and Senate, OCC) H.R. 6244 - (would provide capital relief for community banks, many of them rural-based, that have made limited investments in trust preferred securities (TruPS) issued by other community banks) (All sections) (House and Senate, OCC) H.R. 4099 - Consumer Financial protection Bureau Examination and Reporting Threshold Act (increase the CFPBs examination, enforcement and reporting threshold) (All sections) (House and Senate, OCC) S. 1484 - Financial Regulatory Improvement Act and H.R. 5983 - Financial CHOICE Act - (both contain various community bank regulatory relief measures) (Title 1 in S. 1484) (All sections in H.R. 5983) (House and Senate, OCC) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate, OCC) Comment Letters - Comment Letter - CFPB - Proposed Rule with Request for Public Comment - Payday, Vehicle Title, and Certain High-Cost Installment Loans: Docket No. CFPB-2016-0025 Comment Letter - OCC, FDIC, Federal Reserve and OMB - Proposed Agency Collection Activities (Call Reports), FFIEC 031, FFIEC 041 and FFIEC 051 Comment Letter - IRS - Proposed Rulemaking regarding Estate, Gift, and Generation-Skipping Transfer Taxes; Restrictions on Liquidation of an Interest; 26 CFR Part 25; REG-163112-02; RIN 1545-BB71 Action Alerts - Action Alert - Regarding Payday Lending Rules - Urge CFPB to exempt community banks (CFPB) Action Alert - Regarding Call Reports - Urge OCC, FDIC and the Federal Reserve for meaningful Call Report regulatory relief Action Alert - Regarding IRS estate tax increase - Urge Illinois members of the House to halt backdoor estate tax increases Action Alert - Regarding Lame Duck session - Urge Illinois House and Senate members to pass regulatory relief measures Miscellaneous - Trade Association Industry Letter regarding enacting meaningful regulatory relief measures in the Lame Duck (All sections all bills except where noted) (House and Senate) - The Community Bank Access to Capital Act (H.R. 1523/S. 1816) includes provisions to exempt banks with assets of $50 billion or less from the Basel III regulatory capital rule, and provide an exemption from internal control attestation requirements for community banks with assets of less than $1 billion. The CLEAR Relief Act (S. 812) includes automatic qualified mortgage (QM) status for community bank mortgages held in portfolio. The Home Mortgage Disclosure Adjustment Act (H.R. 4997/S. 3215) provides critical relief for low volume mortgage lenders without materially impacting the mortgage data available to the CFPB or impairing the purpose of the HMDA statute. H.R. 4116/ S. 3373 allows reciprocal deposits to serve as a stable source of funding to support community bank lending by ensuring that reciprocal deposits are not treated by the FDIC as brokered deposits. Right to Lend Act (H.R. 1766) repeals new small business loan data collection requirement. The S Corporation Modernization Act (H.R. 5754/S. 3181) creates an additional source of capital for Subchapter S community banks by allowing them to accept IRA investments. (H.R. 6100/S. 3436) would block a Treasury and IRS proposal to effectively end estate-planning techniques commonly used to transfer community banks and other family-owned businesses to the next generation. (H.R. 6244) would provide capital relief for community banks, many of them rural-based, that have made limited investments in trust preferred securities (TruPS) issued by other community banks. The Financial Regulatory Improvement Act (S. 1484): Title I of S. 1484 includes provisions to promote community bank mortgage lending, including QM status for mortgages held in portfolio; create an exam cycle commensurate with the risk posed by community banks; bring more accountability to exams by the creation of an Ombudsman; and exempt community banks from a Volcker Rule. Regarding the duration, scope and severity of the massive wrongdoing at Wells Fargo, differenced between Main Street and Wall Street, destructive business model, regulatory relief for community banks (House and Senate, OCC)

Community Bankers Association of Illinois (CBAI) 2016 Federal Policy Priorities (House and Senate, OCC) Too-Big-To-Fail Banks and Financial Firms, Our Financial System, Economy, and American Taxpayers - Future Bailouts Reforming the financial system to reduce the possibility, probability, and severity of a future financial crisis - the perception and reality of too-big-to-fail (TBTF) - taxpayer bailouts of mega banks and financial firms - downsize TBTFs Growth, complexity, and interconnection of the TBTF banks - candidates for future bailouts - falling number of community banks representing less than one-fifth of banking professions assets TBTF banks and the mortgage meltdown and financial crisis - protection from massive financial destruction - taxpayer outrage at TBTFs - violations of the law (often criminal) and billions of dollars in fines, settlements and deferred prosecution agreements (conditional amnesty) TBTF effective management, supervision, discipline, and resolution - multi-trillion dollar financial assistance - rightful failure - little assistance for community banks - 500 subsequent failures and devastation U.S. Attorney General Eric Holder admission of a two-tiered system of justice, one for TBTF banks another for everyone else - board resolutions, MOUs, C&Ds, consent orders, monetary penalties, barring individuals from banking, criminal prosecution for community bank, directors, and officers - evidence of a double standard Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank) in Title II - end TBTF bailouts - Wall Street TBTF "single point of entry" (SPOE) plan for resolving failed Systemically Important Financial Institutions (SIFIs) - ensuring future bailouts for SIFIs imposing costs of bailouts on ordinary investors and taxpayers. SIFIs special long-term bonds - conversion to equity when a SIFI fails - sale of bonds to non-systemic investors - ordinary investors primary losers upon conversion into equity - insufficient to recapitalize a failed SIFI, the FDIC borrowing needed funds from the Treasury Department through the Orderly Liquidation Fund (OLF) - OLF current zero balance - backstopped by American taxpayers. Consideration of alternate resolution plans of Arthur Wilmarth, George Washington University Law School - TBTF internalize systemic risks - reduction in size and complexity - prohibition from selling special long-term bonds to ordinary individuals - SIFIs pay risk-adjusted insurance-type premiums to prefund the OLF at a level of $300 billion or more - incentive compensation rule to require SIFIs to pay at least half of total compensation to senior executives and other key employees in the form of contingent convertible bonds - expose insiders to immediate losses if SIFI fail during employment or during post-employment holding period Financial Accounting Standards Board (FASB) Current Expected Credit Loss (CECL) Model Financial Accounting Standards Board (FASB) proposed Current Expected Credit Loss (CECL) model - implications for community banks - prepare financial institutions for a future crisis - use of forward looking information in calculating loan loss reserves The current Incurred Loss model vs. CECL - estimated day one loss and adjust estimated losses continually throughout the life of each loan - pure speculation - CECL models extensive operating system changes and cash flow modeling capabilities - cost and regulatory burden - added reserves - lower future profits, reduce capital levels, decrease community bank lending Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by TBTFs during the financial crisis - different/modest risks posed by community banks - regulations reflecting those differences - regulatory burden on community banks - one-size-fits-all approach - disproportionate burden of banking laws and regulations on community banks Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks - unlevel playing field - a significant competitive disadvantage for community banks Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies Address excessive, redundant and costly regulations - regulatory accountability - community banks dedicating resources to promoting economic growth - steady increase in regulations over many decades - regulatory threats to community banks and their communities. The Plan for Prosperity: Basel III original intent. accurately identify Systemic Risk additional capital for small holding companies - modernizing the Federal Reserves Policy Statement relief from Securities and Exchange Commission (SEC) rules robust housing market - reform mortgage lending community bank mortgage servicing accountability in bank exams - providing a workable appeals process bank oversight and examinations - better target risk risk targeting in the Volker Rule consumer regulation and inclusive and accountable CFPB governance arbitrary disparate impact fair lending causes of action viability of mutual banks - new charter and capital options rigorous and quantitative cost-benefit analysis - justify new rules red tape in small business lending - eliminating burdensome data collection credit for low and moderate income customers and American agriculture subchapter S corporation constraints Limited Liability Corporation (LLC) option for community banks Bank Qualified (BQ) bond issuer limitations five-year loss carryback to support lending during economic downturns. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation distinguishing and appropriately regulating community banks. Credit Union Taxation and Expansion of Powers - Credit unions distinguishable from community banks - grown to control a significant share of the banking services market - outdated original business model - straying from founding purpose of serving individuals of modest means and with a common bond - same financial services as community banks - justification for federal tax-exempt status in exchange for serving their original mission - credit unions paying their fair share of income taxes - credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district - tax subsidy and level the playing field between credit unions and tax-paying community banks Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L) - the exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks] Credit union expansion of commercial lending powers - increasing the percentage of cap on member business lending (MBL) - loan growth at the expense of tax-paying community banks - fundamental altering the exclusive member-focused character of credit unions - condition for their original tax exemption Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts - the same Call Report filing requirements for credit unions as those imposed on community banks Support and cooperation of NCUA the cheerleader regulator of credit unions - expansion of membership proposal - weaken the common bond requirement - disregarding Congressional limits - end around Congress. Farm Credit System (FCS) - Expansionist agenda of the Farm Credit System (FCS) - the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status - tax advantages - unfair competitive advantage - follow narrow historic mission - abolish or be subject to taxation and oversight and regulation Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives Support and cooperation of cheerleader regulator of FCS lenders -Farm Credit Administration (FCA) - straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities - FCS significant systemic and taxpayer bail-out risks FCS (the only GSE) in active competition with community banks - public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks) Funding and tax benefit impact on community banks - not following its narrow historical mission - follow narrow mission or abolish FCSystem - abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks Data, Cyber and Payment Card Security (Data Security) Wide-scale data security breaches at national retail chain stores and other entities - community banks reissuing credit and debit cards at a significant cost - community banks on the frontline of defending against cyber security threats and strong guardians of the security and confidentiality of customer information - central to maintaining public trust and the key to long-term customer retention Core data security principals - cost of data breaches borne by that party that caused the breach - all participants in the payment system (including merchants) should be subject to Gramm-Leach-Bliley Act-like data security standards - a national data security breach and notification standard should replace the current patchwork of state laws - and any new data security standards should ensure that community banks are not burdened with having to implement and comply with new regulations to achieve the same superior results they currently attain - community banks reliance on third party service providers - delicate balance between securing/sharing appropriate customer information Mortgage Lending and Housing Finance Reform Imprudent mortgage lendings contribution to the mortgage meltdown and the financial crisis - community banks common sense relationship lending - no need for prescriptive regulations to compel doing what is right for their customers - not negatively impacting responsible community bank loan products to meet diverse needs of their customers including borrowers with special needs and circumstances, first-time homebuyers, borrowers in rural and underserved areas, and low-to-moderate income borrowers - recognize differences between the non-traditional lending practiced by community banks and the predatory lending practices of others All community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas, receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs) - an increase in the small servicer exemption, an increase in the HMDA reporting levels - a formalized safe harbor during the TRID implementation period - broad special accommodations for community banks to provide flexibility in serving the needs of their customers and communities, particularly in rural areas - and expand definition of underserved areas to include economically challenged areas Untenable long-term position of government sponsored entities (GSEs) Fannie Mae (Fannie) and Freddie Mac (Freddie) in conservatorship by the United States Treasury run by the Federal Housing Finance Agency (FHFA). In reforming to the housing GSEs, the need for the continued existence of an impartial secondary market for residential mortgages for community banks which is financially strong and reliable - the need for some level of government involvement in the secondary market to ensure the continued flow of credit and market liquidity during periods of severe economic stress - no limit in full participation by community banks or disruption in the housing market - the return of private capital to reduce the reliance on government funding - protection of taxpayers from another bailout. Community bank sale of loans through an independent entity - not competing with community banks - no appropriation of community bank customer data for the purpose of cross selling financial services - the Federal Home Loan Banks preserved as a community bank access point (but not the only access point) to the national secondary market - the pricing of the governmental guaranty being fair and equal to all participants regardless of volume of loans guaranteed - no further consolidation of the housing finance system that would result in mega banks and financial firms dominating the market. Consumer Financial Protection Bureau Reform Consumer Financial Protection Bureau (CFPB) use of its statutory authority under the Dodd-Frank Act to exempt community banks or any products or services from the rules it writes - use of this authority to ensure community banks can continue to provide alternatives to large banks and non-banks for consumers seeking responsible financial service providers CFPB providing community banks with flexibility to meet unique needs of customers and not burden community banks with additional and unnecessary regulatory requirements to prevent them from serving their communities - no one-size-fits-all approach to CFPB regulations which harms community banks in meeting the unique needs of its local customers and communities - Community banks enduring any additional consumer regulatory burden on top of the existing burden they already face Single-Director governance of the CFPB vs. a five-member commission - residential regulators participate with the CFPB in the rule-writing process - Financial Stability Oversight Council (FSOC) power to veto CFPB rules under a practical and realistic standard - a broad definition of firms that grant credit being subject to the CFPB rules, and their supervision and examination Focus of any enhanced regulation of financial products on TBTF banks and financial firms and the unregulated shadow financial industry - efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products - holding all of the other financial service providers up to the existing high standards for compliance with consumer laws, rules and regulations as currently attained by community banks De Novo Community Bank Formation and the Dual Banking System/Charter Choice Newly chartered (de novo) community banks importance in maintaining a strong, growing, evolving and vibrant banking profession - FDICs inhibiting de novo community bank formation during the financial crisis, FDICs indication of a change in policy direction by rescinding its Financial Institution Letter (FIL) 50-2009, Enhanced Supervisory Procedures for Newly Insured FDIC-Supervised Depository Institutions The importance of the dual banking system where chartering and supervision is divided between the federal government and the states - community banks choice of charters that best fits their business model - multi-agency (state and federal) regulators and charter choice providing necessary checks and balances on the power of the regulators, as well as improved rulemaking, the benefit of each agencies expertise and experience is brought to bear on complex and controversial issues Federal Home Loan Bank System Federal Home Loan Banks (FHLBs) strong partnership with community banks - providing short-term liquidity, long-term funding and other financial products that serve the needs of all member-owners - providing lendable funds for the local communities - regional structure, special functions and purposes of the FHLBs recognized and maintained by the Federal Housing Finance Agency (FHFA). FHFAs proposed rulemaking to revise FHLB membership eligibility requirements - negative impact on the FHLB System and its members - precedent set to terminate through rulemaking FHLB membership and the threat to revisit the broader membership issue in the future - contrary to the will of Congress FHLB System position as a healthy, stable and reliable source of funding for its members - not as the sole aggregator or securitizer of residential mortgages for community banks - FHFAs imposition of an ongoing housing mission asset test on community financial institutions Excessive Intervention in Monetary Policy Sustained record-low zero interest rate policy (ZIRP) engineered and implemented by the Federal Reserve System - disproportionally impact on community banks, senior citizens and savers - a significant drag on the earnings of community banks - THBF banks with non-traditional banking business lines derive a much lower percentage of their earnings from net interest margins and are not as negatively impacted - limits to what Fed monetary policy can accomplish considering major offsetting negative effects on community banks, senior citizens, and savers Legislation - H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate, OCC) H.R. 4500 and S. 927 - CLEAR Relief Act Plus Act (Call report regulatory relief for community banks) (All sections) (House and Senate, OCC) H.R.1523 and S. 1816 - Community Bank Access to Capital Act (exempt banks with assets of $50 billion or less from the Basel III regulatory capital rule, and provide an exemption from internal control attestation requirements for community banks with assets of less than $1 billion) (All sections) (House and Senate, OCC) H.R. 1210 and S. 2995 - Portfolio Lending and Mortgage Access Act (automatic Qualified Mortgage (QM) protection for community bank mortgages held in portfolio) (All sections) (House and Senate, OCC) H.R. 4993 - Homeowners Information Privacy Protection Act (study privacy implications of new HMDA data fields) (All sections) (House and Senate, OCC) H.R. 4997 and S. 3215 - Home Mortgage Disclosure Adjustment Act (HMDA reporting relief for low volume mortgage lenders) (All sections) (House and Senate, OCC) H.R. 4950 - Small Financial Institution Advisory Committee Act of 2016 (creates a Treasury Department community bank advisory committee) (All sections) (House and Senate, OCC) H.R. 5733 - Beginning Farmer and Rancher Guaranteed Loan Modernization Act (modifies limits applicable to qualified conservation loan guarantees) (All sections) (House and Senate, OCC) H.R. 4116/ S. 3373 (allows reciprocal deposits to serve as a stable source of funding to support community bank lending by ensuring that reciprocal deposits are not treated by the FDIC as brokered deposits.) (All sections) (House and Senate, OCC) H.R. 1766 - Right to Lend Act (repeals new small business loan data collection requirement) (All sections) (House and Senate, OCC) H.R. 5754 and S. 3181 - S Corporation Modernization Act (creates an additional source of capital for Subchapter S community banks by allowing them to accept IRA investments) (All sections) (House and Senate, OCC) H.R. 6100 and S. 3436 - (would block a Treasury and IRS proposal to effectively end estate-planning techniques commonly used to transfer community banks and other family-owned businesses to the next generation) (All Sections) (House and Senate, OCC) H.R. 6244 - (would provide capital relief for community banks, many of them rural-based, that have made limited investments in trust preferred securities (TruPS) issued by other community banks) (All sections) (House and Senate, OCC) H.R. 4099 - Consumer Financial protection Bureau Examination and Reporting Threshold Act (increase the CFPBs examination, enforcement and reporting threshold) (All sections) (House and Senate, OCC) S. 1484 - Financial Regulatory Improvement Act and H.R. 5983 - Financial CHOICE Act - (both contain various community bank regulatory relief measures) (Title 1 in S. 1484) (All sections in H.R. 5983) (House and Senate, OCC) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate, OCC) Comment Letters - Comment Letter - CFPB - Proposed Rule with Request for Public Comment - Payday, Vehicle Title, and Certain High-Cost Installment Loans: Docket No. CFPB-2016-0025 Comment Letter - OCC, FDIC, Federal Reserve and OMB - Proposed Agency Collection Activities (Call Reports), FFIEC 031, FFIEC 041 and FFIEC 051 Comment Letter - IRS - Proposed Rulemaking regarding Estate, Gift, and Generation-Skipping Transfer Taxes; Restrictions on Liquidation of an Interest; 26 CFR Part 25; REG-163112-02; RIN 1545-BB71 Action Alerts - Action Alert - Regarding Payday Lending Rules - Urge CFPB to exempt community banks (CFPB) Action Alert - Regarding Call Reports - Urge OCC, FDIC and the Federal Reserve for meaningful Call Report regulatory relief Action Alert - Regarding IRS estate tax increase - Urge Illinois members of the House to halt backdoor estate tax increases Action Alert - Regarding Lame Duck session - Urge Illinois House and Senate members to pass regulatory relief measures Miscellaneous - Trade Association Industry Letter regarding enacting meaningful regulatory relief measures in the Lame Duck (All sections all bills except where noted) (House and Senate) - The Community Bank Access to Capital Act (H.R. 1523/S. 1816) includes provisions to exempt banks with assets of $50 billion or less from the Basel III regulatory capital rule, and provide an exemption from internal control attestation requirements for community banks with assets of less than $1 billion. The CLEAR Relief Act (S. 812) includes automatic qualified mortgage (QM) status for community bank mortgages held in portfolio. The Home Mortgage Disclosure Adjustment Act (H.R. 4997/S. 3215) provides critical relief for low volume mortgage lenders without materially impacting the mortgage data available to the CFPB or impairing the purpose of the HMDA statute. H.R. 4116/ S. 3373 allows reciprocal deposits to serve as a stable source of funding to support community bank lending by ensuring that reciprocal deposits are not treated by the FDIC as brokered deposits. Right to Lend Act (H.R. 1766) repeals new small business loan data collection requirement. The S Corporation Modernization Act (H.R. 5754/S. 3181) creates an additional source of capital for Subchapter S community banks by allowing them to accept IRA investments. (H.R. 6100/S. 3436) would block a Treasury and IRS proposal to effectively end estate-planning techniques commonly used to transfer community banks and other family-owned businesses to the next generation. (H.R. 6244) would provide capital relief for community banks, many of them rural-based, that have made limited investments in trust preferred securities (TruPS) issued by other community banks. The Financial Regulatory Improvement Act (S. 1484): Title I of S. 1484 includes provisions to promote community bank mortgage lending, including QM status for mortgages held in portfolio; create an exam cycle commensurate with the risk posed by community banks; bring more accountability to exams by the creation of an Ombudsman; and exempt community banks from a Volcker Rule. Regarding the duration, scope and severity of the massive wrongdoing at Wells Fargo, differenced between Main Street and Wall Street, destructive business model, regulatory relief for community banks (House and Senate, OCC)

Community Bankers Association of Illinois (CBAI) 2016 Federal Policy Priorities (House and Senate, OCC) Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by TBTFs during the financial crisis - different/modest risks posed by community banks - regulations reflecting those differences - regulatory burden on community banks - one-size-fits-all approach - disproportionate burden of banking laws and regulations on community banks Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks - unlevel playing field - a significant competitive disadvantage for community banks Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies Address excessive, redundant and costly regulations - regulatory accountability - community banks dedicating resources to promoting economic growth - steady increase in regulations over many decades - regulatory threats to community banks and their communities. The Plan for Prosperity: Basel III original intent. accurately identify Systemic Risk additional capital for small holding companies - modernizing the Federal Reserves Policy Statement relief from Securities and Exchange Commission (SEC) rules robust housing market - reform mortgage lending community bank mortgage servicing accountability in bank exams - providing a workable appeals process bank oversight and examinations - better target risk risk targeting in the Volker Rule consumer regulation and inclusive and accountable CFPB governance arbitrary disparate impact fair lending causes of action viability of mutual banks - new charter and capital options rigorous and quantitative cost-benefit analysis - justify new rules red tape in small business lending - eliminating burdensome data collection credit for low and moderate income customers and American agriculture subchapter S corporation constraints Limited Liability Corporation (LLC) option for community banks Bank Qualified (BQ) bond issuer limitations five-year loss carryback to support lending during economic downturns. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation distinguishing and appropriately regulating community banks. Data, Cyber and Payment Card Security (Data Security) Wide-scale data security breaches at national retail chain stores and other entities - community banks reissuing credit and debit cards at a significant cost - community banks on the frontline of defending against cyber security threats and strong guardians of the security and confidentiality of customer information - central to maintaining public trust and the key to long-term customer retention Core data security principals - cost of data breaches borne by that party that caused the breach - all participants in the payment system (including merchants) should be subject to Gramm-Leach-Bliley Act-like data security standards - a national data security breach and notification standard should replace the current patchwork of state laws - and any new data security standards should ensure that community banks are not burdened with having to implement and comply with new regulations to achieve the same superior results they currently attain - community banks reliance on third party service providers - delicate balance between securing/sharing appropriate customer information Credit Union Taxation and Expansion of Powers - Credit unions distinguishable from community banks - grown to control a significant share of the banking services market - outdated original business model - straying from founding purpose of serving individuals of modest means and with a common bond - same financial services as community banks - justification for federal tax-exempt status in exchange for serving their original mission - credit unions paying their fair share of income taxes - credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district - tax subsidy and level the playing field between credit unions and tax-paying community banks Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L) - the exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks] Credit union expansion of commercial lending powers - increasing the percentage of cap on member business lending (MBL) - loan growth at the expense of tax-paying community banks - fundamental altering the exclusive member-focused character of credit unions - condition for their original tax exemption Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts - the same Call Report filing requirements for credit unions as those imposed on community banks Support and cooperation of NCUA the cheerleader regulator of credit unions - expansion of membership proposal - weaken the common bond requirement - disregarding Congressional limits - end around Congress. Legislation - H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate, OCC) H.R. 1766 - Right to Lend Act (repeals new small business loan data collection requirement) (All sections) (House and Senate, OCC) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate, OCC) Action Alerts - Action Alert - Regarding Lame Duck session - Urge Illinois House and Senate members to pass regulatory relief measures Miscellaneous - Trade Association Industry Letter regarding enacting meaningful regulatory relief measures in the Lame Duck (All sections) (House and Senate) - Right to Lend Act (H.R. 1766) repeals new small business loan data collection requirement.

Community Bankers Association of Illinois (CBAI) 2016 Federal Policy Priorities (House and Senate, OCC) Credit Union Taxation and Expansion of Powers - Credit unions distinguishable from community banks - grown to control a significant share of the banking services market - outdated original business model - straying from founding purpose of serving individuals of modest means and with a common bond - same financial services as community banks - justification for federal tax-exempt status in exchange for serving their original mission - credit unions paying their fair share of income taxes - credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district - tax subsidy and level the playing field between credit unions and tax-paying community banks Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L) - the exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks] Credit union expansion of commercial lending powers - increasing the percentage of cap on member business lending (MBL) - loan growth at the expense of tax-paying community banks - fundamental altering the exclusive member-focused character of credit unions - condition for their original tax exemption Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts - the same Call Report filing requirements for credit unions as those imposed on community banks Support and cooperation of NCUA the cheerleader regulator of credit unions - expansion of membership proposal - weaken the common bond requirement - disregarding Congressional limits - end around Congress. Farm Credit System (FCS) - Expansionist agenda of the Farm Credit System (FCS) - the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status - tax advantages - unfair competitive advantage - follow narrow historic mission - abolish or be subject to taxation and oversight and regulation Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives Support and cooperation of cheerleader regulator of FCS lenders -Farm Credit Administration (FCA) - straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities - FCS significant systemic and taxpayer bail-out risks FCS (the only GSE) in active competition with community banks - public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks) Funding and tax benefit impact on community banks - not following its narrow historical mission - follow narrow mission or abolish FCSystem - abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by TBTFs during the financial crisis - different/modest risks posed by community banks - regulations reflecting those differences - regulatory burden on community banks - one-size-fits-all approach - disproportionate burden of banking laws and regulations on community banks Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks - unlevel playing field - a significant competitive disadvantage for community banks Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies Address excessive, redundant and costly regulations - regulatory accountability - community banks dedicating resources to promoting economic growth - steady increase in regulations over many decades - regulatory threats to community banks and their communities. The Plan for Prosperity: Basel III original intent. accurately identify Systemic Risk additional capital for small holding companies - modernizing the Federal Reserves Policy Statement relief from Securities and Exchange Commission (SEC) rules robust housing market - reform mortgage lending community bank mortgage servicing accountability in bank exams - providing a workable appeals process bank oversight and examinations - better target risk risk targeting in the Volker Rule consumer regulation and inclusive and accountable CFPB governance arbitrary disparate impact fair lending causes of action viability of mutual banks - new charter and capital options rigorous and quantitative cost-benefit analysis - justify new rules red tape in small business lending - eliminating burdensome data collection credit for low and moderate income customers and American agriculture subchapter S corporation constraints Limited Liability Corporation (LLC) option for community banks Bank Qualified (BQ) bond issuer limitations five-year loss carryback to support lending during economic downturns. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation distinguishing and appropriately regulating community banks. Legislation - H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate, OCC) H.R. 5754 and S. 3181 - S Corporation Modernization Act (creates an additional source of capital for Subchapter S community banks by allowing them to accept IRA investments) (All sections) (House and Senate, OCC) H.R. 6100 and S. 3436 - (would block a Treasury and IRS proposal to effectively end estate-planning techniques commonly used to transfer community banks and other family-owned businesses to the next generation) (All Sections) (House and Senate, OCC) S. 1484 - Financial Regulatory Improvement Act and H.R. 5983 - Financial CHOICE Act - (both contain various community bank regulatory relief measures) (Title 1 in S. 1484) (All sections in H.R. 5983) (House and Senate, OCC) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate, OCC) Comment Letters - Comment Letter - IRS - Proposed Rulemaking Regarding Estate, Gift, and Generation-Skipping Transfer Taxes; Restrictions on Liquidation of an Interest; 26 CFR Part 25; REG-163112-02; RIN 1545-BB71 Action Alert - Action Alert - Regarding IRS estate tax increase - Urge Illinois members of the House to halt backdoor estate tax increases Miscellaneous - Trade Association Industry Letter regarding enacting meaningful regulatory relief measures in the Lame Duck (All sections all bills except where noted) (House and Senate) - The S Corporation Modernization Act (H.R. 5754/S. 3181) creates an additional source of capital for Subchapter S community banks by allowing them to accept IRA investments. (H.R. 6100/S. 3436) would block a Treasury and IRS proposal to effectively end estate-planning techniques commonly used to transfer community banks and other family-owned businesses to the next generation. The Financial Regulatory Improvement Act (S. 1484): Title I of S. 1484 includes provisions to promote community bank mortgage lending, including QM status for mortgages held in portfolio; create an exam cycle commensurate with the risk posed by community banks; bring more accountability to exams by the creation of an Ombudsman; and exempt community banks from a Volcker Rule.

Community Bankers Association of Illinois (CBAI) 2016 Federal Policy Priorities (House and Senate, Federal Reserve) Too-Big-To-Fail Banks and Financial Firms, Our Financial System, Economy, and American Taxpayers - Future Bailouts Reforming the financial system to reduce the possibility, probability, and severity of a future financial crisis - the perception and reality of too-big-to-fail (TBTF) - taxpayer bailouts of mega banks and financial firms - downsize TBTFs Growth, complexity, and interconnection of the TBTF banks - candidates for future bailouts - falling number of community banks representing less than one-fifth of banking professions assets TBTF banks and the mortgage meltdown and financial crisis - protection from massive financial destruction - taxpayer outrage at TBTFs - violations of the law (often criminal) and billions of dollars in fines, settlements and deferred prosecution agreements (conditional amnesty) TBTF effective management, supervision, discipline, and resolution - multi-trillion dollar financial assistance - rightful failure - little assistance for community banks - 500 subsequent failures and devastation U.S. Attorney General Eric Holder admission of a two-tiered system of justice, one for TBTF banks another for everyone else - board resolutions, MOUs, C&Ds, consent orders, monetary penalties, barring individuals from banking, criminal prosecution for community bank, directors, and officers - evidence of a double standard Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank) in Title II - end TBTF bailouts - Wall Street TBTF "single point of entry" (SPOE) plan for resolving failed Systemically Important Financial Institutions (SIFIs) - ensuring future bailouts for SIFIs imposing costs of bailouts on ordinary investors and taxpayers. SIFIs special long-term bonds - conversion to equity when a SIFI fails - sale of bonds to non-systemic investors - ordinary investors primary losers upon conversion into equity - insufficient to recapitalize a failed SIFI, the FDIC borrowing needed funds from the Treasury Department through the Orderly Liquidation Fund (OLF) - OLF current zero balance - backstopped by American taxpayers. Consideration of alternate resolution plans of Arthur Wilmarth, George Washington University Law School - TBTF internalize systemic risks - reduction in size and complexity - prohibition from selling special long-term bonds to ordinary individuals - SIFIs pay risk-adjusted insurance-type premiums to prefund the OLF at a level of $300 billion or more - incentive compensation rule to require SIFIs to pay at least half of total compensation to senior executives and other key employees in the form of contingent convertible bonds - expose insiders to immediate losses if SIFI fail during employment or during post-employment holding period Financial Accounting Standards Board (FASB) Current Expected Credit Loss (CECL) Model Financial Accounting Standards Board (FASB) proposed Current Expected Credit Loss (CECL) model - implications for community banks - prepare financial institutions for a future crisis - use of forward looking information in calculating loan loss reserves The current Incurred Loss model vs. CECL - estimated day one loss and adjust estimated losses continually throughout the life of each loan - pure speculation - CECL models extensive operating system changes and cash flow modeling capabilities - cost and regulatory burden - added reserves - lower future profits, reduce capital levels, decrease community bank lending Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by TBTFs during the financial crisis - different/modest risks posed by community banks - regulations reflecting those differences - regulatory burden on community banks - one-size-fits-all approach - disproportionate burden of banking laws and regulations on community banks Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks - unlevel playing field - a significant competitive disadvantage for community banks Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies Address excessive, redundant and costly regulations - regulatory accountability - community banks dedicating resources to promoting economic growth - steady increase in regulations over many decades - regulatory threats to community banks and their communities. The Plan for Prosperity: Basel III original intent. accurately identify Systemic Risk additional capital for small holding companies - modernizing the Federal Reserves Policy Statement relief from Securities and Exchange Commission (SEC) rules robust housing market - reform mortgage lending community bank mortgage servicing accountability in bank exams - providing a workable appeals process bank oversight and examinations - better target risk risk targeting in the Volker Rule consumer regulation and inclusive and accountable CFPB governance arbitrary disparate impact fair lending causes of action viability of mutual banks - new charter and capital options rigorous and quantitative cost-benefit analysis - justify new rules red tape in small business lending - eliminating burdensome data collection credit for low and moderate income customers and American agriculture subchapter S corporation constraints Limited Liability Corporation (LLC) option for community banks Bank Qualified (BQ) bond issuer limitations five-year loss carryback to support lending during economic downturns. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation distinguishing and appropriately regulating community banks. Credit Union Taxation and Expansion of Powers - Credit unions distinguishable from community banks - grown to control a significant share of the banking services market - outdated original business model - straying from founding purpose of serving individuals of modest means and with a common bond - same financial services as community banks - justification for federal tax-exempt status in exchange for serving their original mission - credit unions paying their fair share of income taxes - credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district - tax subsidy and level the playing field between credit unions and tax-paying community banks Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L) - the exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks] Credit union expansion of commercial lending powers - increasing the percentage of cap on member business lending (MBL) - loan growth at the expense of tax-paying community banks - fundamental altering the exclusive member-focused character of credit unions - condition for their original tax exemption Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts - the same Call Report filing requirements for credit unions as those imposed on community banks Support and cooperation of NCUA the cheerleader regulator of credit unions - expansion of membership proposal - weaken the common bond requirement - disregarding Congressional limits - end around Congress. Farm Credit System (FCS) - Expansionist agenda of the Farm Credit System (FCS) - the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status - tax advantages - unfair competitive advantage - follow narrow historic mission - abolish or be subject to taxation and oversight and regulation Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives Support and cooperation of cheerleader regulator of FCS lenders -Farm Credit Administration (FCA) - straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities - FCS significant systemic and taxpayer bail-out risks FCS (the only GSE) in active competition with community banks - public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks) Funding and tax benefit impact on community banks - not following its narrow historical mission - follow narrow mission or abolish FCSystem - abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks Data, Cyber and Payment Card Security (Data Security) Wide-scale data security breaches at national retail chain stores and other entities - community banks reissuing credit and debit cards at a significant cost - community banks on the frontline of defending against cyber security threats and strong guardians of the security and confidentiality of customer information - central to maintaining public trust and the key to long-term customer retention Core data security principals - cost of data breaches borne by that party that caused the breach - all participants in the payment system (including merchants) should be subject to Gramm-Leach-Bliley Act-like data security standards - a national data security breach and notification standard should replace the current patchwork of state laws - and any new data security standards should ensure that community banks are not burdened with having to implement and comply with new regulations to achieve the same superior results they currently attain - community banks reliance on third party service providers - delicate balance between securing/sharing appropriate customer information Mortgage Lending and Housing Finance Reform Imprudent mortgage lendings contribution to the mortgage meltdown and the financial crisis - community banks common sense relationship lending - no need for prescriptive regulations to compel doing what is right for their customers - not negatively impacting responsible community bank loan products to meet diverse needs of their customers including borrowers with special needs and circumstances, first-time homebuyers, borrowers in rural and underserved areas, and low-to-moderate income borrowers - recognize differences between the non-traditional lending practiced by community banks and the predatory lending practices of others All community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas, receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs) - an increase in the small servicer exemption, an increase in the HMDA reporting levels - a formalized safe harbor during the TRID implementation period - broad special accommodations for community banks to provide flexibility in serving the needs of their customers and communities, particularly in rural areas - and expand definition of underserved areas to include economically challenged areas Untenable long-term position of government sponsored entities (GSEs) Fannie Mae (Fannie) and Freddie Mac (Freddie) in conservatorship by the United States Treasury run by the Federal Housing Finance Agency (FHFA). In reforming to the housing GSEs, the need for the continued existence of an impartial secondary market for residential mortgages for community banks which is financially strong and reliable - the need for some level of government involvement in the secondary market to ensure the continued flow of credit and market liquidity during periods of severe economic stress - no limit in full participation by community banks or disruption in the housing market - the return of private capital to reduce the reliance on government funding - protection of taxpayers from another bailout. Community bank sale of loans through an independent entity - not competing with community banks - no appropriation of community bank customer data for the purpose of cross selling financial services - the Federal Home Loan Banks preserved as a community bank access point (but not the only access point) to the national secondary market - the pricing of the governmental guaranty being fair and equal to all participants regardless of volume of loans guaranteed - no further consolidation of the housing finance system that would result in mega banks and financial firms dominating the market. Consumer Financial Protection Bureau Reform Consumer Financial Protection Bureau (CFPB) use of its statutory authority under the Dodd-Frank Act to exempt community banks or any products or services from the rules it writes - use of this authority to ensure community banks can continue to provide alternatives to large banks and non-banks for consumers seeking responsible financial service providers CFPB providing community banks with flexibility to meet unique needs of customers and not burden community banks with additional and unnecessary regulatory requirements to prevent them from serving their communities - no one-size-fits-all approach to CFPB regulations which harms community banks in meeting the unique needs of its local customers and communities - Community banks enduring any additional consumer regulatory burden on top of the existing burden they already face Single-Director governance of the CFPB vs. a five-member commission - residential regulators participate with the CFPB in the rule-writing process - Financial Stability Oversight Council (FSOC) power to veto CFPB rules under a practical and realistic standard - a broad definition of firms that grant credit being subject to the CFPB rules, and their supervision and examination Focus of any enhanced regulation of financial products on TBTF banks and financial firms and the unregulated shadow financial industry - efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products - holding all of the other financial service providers up to the existing high standards for compliance with consumer laws, rules and regulations as currently attained by community banks De Novo Community Bank Formation and the Dual Banking System/Charter Choice Newly chartered (de novo) community banks importance in maintaining a strong, growing, evolving and vibrant banking profession - FDICs inhibiting de novo community bank formation during the financial crisis, FDICs indication of a change in policy direction by rescinding its Financial Institution Letter (FIL) 50-2009, Enhanced Supervisory Procedures for Newly Insured FDIC-Supervised Depository Institutions The importance of the dual banking system where chartering and supervision is divided between the federal government and the states - community banks choice of charters that best fits their business model - multi-agency (state and federal) regulators and charter choice providing necessary checks and balances on the power of the regulators, as well as improved rulemaking, the benefit of each agencies expertise and experience is brought to bear on complex and controversial issues Federal Home Loan Bank System Federal Home Loan Banks (FHLBs) strong partnership with community banks - providing short-term liquidity, long-term funding and other financial products that serve the needs of all member-owners - providing lendable funds for the local communities - regional structure, special functions and purposes of the FHLBs recognized and maintained by the Federal Housing Finance Agency (FHFA). FHFAs proposed rulemaking to revise FHLB membership eligibility requirements - negative impact on the FHLB System and its members - precedent set to terminate through rulemaking FHLB membership and the threat to revisit the broader membership issue in the future - contrary to the will of Congress FHLB System position as a healthy, stable and reliable source of funding for its members - not as the sole aggregator or securitizer of residential mortgages for community banks - FHFAs imposition of an ongoing housing mission asset test on community financial institutions Excessive Intervention in Monetary Policy Sustained record-low zero interest rate policy (ZIRP) engineered and implemented by the Federal Reserve System - disproportionally impact on community banks, senior citizens and savers - a significant drag on the earnings of community banks - THBF banks with non-traditional banking business lines derive a much lower percentage of their earnings from net interest margins and are not as negatively impacted - limits to what Fed monetary policy can accomplish considering major offsetting negative effects on community banks, senior citizens, and savers Legislation - H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate) H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate) H.R. 4993 - Homeowners Information Privacy Protection Act (study privacy implications of new HMDA data fields) (All sections) (House and Senate) H.R. 4950 - Small Financial Institution Advisory Committee Act of 2016 (creates a Treasury Department community bank advisory committee) (All sections) (House and Senate) Comment Letters - Comment Letter - OCC, FDIC and Federal Reserve - Incentive-Based Compensation Arrangements: OCC 12 CFR Part 42, Docket No. OCC-2011-0001, RIN 1557-AD39; Federal Reserve System 12 CFR Part 236, Docket No. R-1536, RIN 7100 AE-50; Federal Deposit Insurance Corporation 12 CFR Part 372, RIN 3064-AD86 Miscellaneous - Regarding Federal Reserve Bank of Chicago meeting - dual banking system, electronic delivery of loan files for examinations, prolonged low interest rate environment, shared examination responsibility with other regulators, Financial Accounting Standards Boards (FASB) Current Expected Credit Loss model (CECL) (Federal Reserve) Regarding letter to Illinois Congressional Delegation - the duration, scope and severity of the massive wrongdoing at Wells Fargo, differenced between Main Street and Wall Street, destructive business model, regulatory relief for community banks (House and Senate) Regarding House meeting - Treasury Department community bank study and Treasury Department Community Bank Advisory Committee (House)

Community Bankers Association of Illinois (CBAI) 2016 Federal Policy Priorities (House and Senate, Federal Reserve) Farm Credit System (FCS) - Expansionist agenda of the Farm Credit System (FCS) - the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status - tax advantages - unfair competitive advantage - follow narrow historic mission - abolish or be subject to taxation and oversight and regulation Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives Support and cooperation of cheerleader regulator of FCS lenders -Farm Credit Administration (FCA) - straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities - FCS significant systemic and taxpayer bail-out risks FCS (the only GSE) in active competition with community banks - public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks) Funding and tax benefit impact on community banks - not following its narrow historical mission - follow narrow mission or abolish FCSystem - abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks

Community Bankers Association of Illinois (CBAI) 2016 Federal Policy Priorities (House and Senate, Federal Reserve) Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by TBTFs during the financial crisis - different/modest risks posed by community banks - regulations reflecting those differences - regulatory burden on community banks - one-size-fits-all approach - disproportionate burden of banking laws and regulations on community banks Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks - unlevel playing field - a significant competitive disadvantage for community banks Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies Address excessive, redundant and costly regulations - regulatory accountability - community banks dedicating resources to promoting economic growth - steady increase in regulations over many decades - regulatory threats to community banks and their communities. The Plan for Prosperity: Basel III original intent. accurately identify Systemic Risk additional capital for small holding companies - modernizing the Federal Reserves Policy Statement relief from Securities and Exchange Commission (SEC) rules robust housing market - reform mortgage lending community bank mortgage servicing accountability in bank exams - providing a workable appeals process bank oversight and examinations - better target risk risk targeting in the Volker Rule consumer regulation and inclusive and accountable CFPB governance arbitrary disparate impact fair lending causes of action viability of mutual banks - new charter and capital options rigorous and quantitative cost-benefit analysis - justify new rules red tape in small business lending - eliminating burdensome data collection credit for low and moderate income customers and American agriculture subchapter S corporation constraints Limited Liability Corporation (LLC) option for community banks Bank Qualified (BQ) bond issuer limitations five-year loss carryback to support lending during economic downturns. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation distinguishing and appropriately regulating community banks. Data, Cyber and Payment Card Security (Data Security) Wide-scale data security breaches at national retail chain stores and other entities - community banks reissuing credit and debit cards at a significant cost - community banks on the frontline of defending against cyber security threats and strong guardians of the security and confidentiality of customer information - central to maintaining public trust and the key to long-term customer retention Core data security principals - cost of data breaches borne by that party that caused the breach - all participants in the payment system (including merchants) should be subject to Gramm-Leach-Bliley Act-like data security standards - a national data security breach and notification standard should replace the current patchwork of state laws - and any new data security standards should ensure that community banks are not burdened with having to implement and comply with new regulations to achieve the same superior results they currently attain - community banks reliance on third party service providers - delicate balance between securing/sharing appropriate customer information Credit Union Taxation and Expansion of Powers - Credit unions distinguishable from community banks - grown to control a significant share of the banking services market - outdated original business model - straying from founding purpose of serving individuals of modest means and with a common bond - same financial services as community banks - justification for federal tax-exempt status in exchange for serving their original mission - credit unions paying their fair share of income taxes - credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district - tax subsidy and level the playing field between credit unions and tax-paying community banks Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L) - the exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks] Credit union expansion of commercial lending powers - increasing the percentage of cap on member business lending (MBL) - loan growth at the expense of tax-paying community banks - fundamental altering the exclusive member-focused character of credit unions - condition for their original tax exemption Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts - the same Call Report filing requirements for credit unions as those imposed on community banks Support and cooperation of NCUA the cheerleader regulator of credit unions - expansion of membership proposal - weaken the common bond requirement - disregarding Congressional limits - end around Congress. Legislation - H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate)

Community Bankers Association of Illinois (CBAI) 2016 Federal Policy Priorities (House and Senate, Federal Reserve) Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by TBTFs during the financial crisis - different/modest risks posed by community banks - regulations reflecting those differences - regulatory burden on community banks - one-size-fits-all approach - disproportionate burden of banking laws and regulations on community banks Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks - unlevel playing field - a significant competitive disadvantage for community banks Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies Address excessive, redundant and costly regulations - regulatory accountability - community banks dedicating resources to promoting economic growth - steady increase in regulations over many decades - regulatory threats to community banks and their communities The Plan for Prosperity: Basel III original intent. accurately identify Systemic Risk additional capital for small holding companies - modernizing the Federal Reserves Policy Statement relief from Securities and Exchange Commission (SEC) rules robust housing market - reform mortgage lending community bank mortgage servicing accountability in bank exams - providing a workable appeals process bank oversight and examinations - better target risk risk targeting in the Volker Rule consumer regulation and inclusive and accountable CFPB governance arbitrary disparate impact fair lending causes of action viability of mutual banks - new charter and capital options rigorous and quantitative cost-benefit analysis - justify new rules red tape in small business lending - eliminating burdensome data collection credit for low and moderate income customers and American agriculture subchapter S corporation constraints Limited Liability Corporation (LLC) option for community banks Bank Qualified (BQ) bond issuer limitations five-year loss carryback to support lending during economic downturns. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation distinguishing and appropriately regulating community banks. Data, Cyber and Payment Card Security (Data Security) Wide-scale data security breaches at national retail chain stores and other entities - community banks reissuing credit and debit cards at a significant cost - community banks on the frontline of defending against cyber security threats and strong guardians of the security and confidentiality of customer information - central to maintaining public trust and the key to long-term customer retention Core data security principals - cost of data breaches borne by that party that caused the breach - all participants in the payment system (including merchants) should be subject to Gramm-Leach-Bliley Act-like data security standards - a national data security breach and notification standard should replace the current patchwork of state laws - and any new data security standards should ensure that community banks are not burdened with having to implement and comply with new regulations to achieve the same superior results they currently attain - community banks reliance on third party service providers - delicate balance between securing/sharing appropriate customer information Mortgage Lending and Housing Finance Reform Imprudent mortgage lendings contribution to the mortgage meltdown and the financial crisis - community banks common sense relationship lending - no need for prescriptive regulations to compel doing what is right for their customers - not negatively impacting responsible community bank loan products to meet diverse needs of their customers including borrowers with special needs and circumstances, first-time homebuyers, borrowers in rural and underserved areas, and low-to-moderate income borrowers - recognize differences between the non-traditional lending practiced by community banks and the predatory lending practices of others All community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas, receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs) - an increase in the small servicer exemption, an increase in the HMDA reporting levels - a formalized safe harbor during the TRID implementation period - broad special accommodations for community banks to provide flexibility in serving the needs of their customers and communities, particularly in rural areas - and expand definition of underserved areas to include economically challenged areas Untenable long-term position of government sponsored entities (GSEs) Fannie Mae (Fannie) and Freddie Mac (Freddie) in conservatorship by the United States Treasury run by the Federal Housing Finance Agency (FHFA). In reforming to the housing GSEs, the need for the continued existence of an impartial secondary market for residential mortgages for community banks which is financially strong and reliable - the need for some level of government involvement in the secondary market to ensure the continued flow of credit and market liquidity during periods of severe economic stress - no limit in full participation by community banks or disruption in the housing market - the return of private capital to reduce the reliance on government funding - protection of taxpayers from another bailout. Community bank sale of loans through an independent entity - not competing with community banks - no appropriation of community bank customer data for the purpose of cross selling financial services - the Federal Home Loan Banks preserved as a community bank access point (but not the only access point) to the national secondary market - the pricing of the governmental guaranty being fair and equal to all participants regardless of volume of loans guaranteed - no further consolidation of the housing finance system that would result in mega banks and financial firms dominating the market. Consumer Financial Protection Bureau Reform Consumer Financial Protection Bureau (CFPB) use of its statutory authority under the Dodd-Frank Act to exempt community banks or any products or services from the rules it writes - use of this authority to ensure community banks can continue to provide alternatives to large banks and non-banks for consumers seeking responsible financial service providers CFPB providing community banks with flexibility to meet unique needs of customers and not burden community banks with additional and unnecessary regulatory requirements to prevent them from serving their communities - no one-size-fits-all approach to CFPB regulations which harms community banks in meeting the unique needs of its local customers and communities - Community banks enduring any additional consumer regulatory burden on top of the existing burden they already face Single-Director governance of the CFPB vs. a five-member commission - residential regulators participate with the CFPB in the rule-writing process - Financial Stability Oversight Council (FSOC) power to veto CFPB rules under a practical and realistic standard - a broad definition of firms that grant credit being subject to the CFPB rules, and their supervision and examination Focus of any enhanced regulation of financial products on TBTF banks and financial firms and the unregulated shadow financial industry - efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products - holding all of the other financial service providers up to the existing high standards for compliance with consumer laws, rules and regulations as currently attained by community banks Excessive Intervention in Monetary Policy Sustained record-low zero interest rate policy (ZIRP) engineered and implemented by the Federal Reserve System - disproportionally impact on community banks, senior citizens and savers - a significant drag on the earnings of community banks - THBF banks with non-traditional banking business lines derive a much lower percentage of their earnings from net interest margins and are not as negatively impacted - limits to what Fed monetary policy can accomplish considering major offsetting negative effects on community banks, senior citizens, and savers Legislation - H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate) H.R. 4993 - Homeowners Information Privacy Protection Act (study privacy implications of new HMDA data fields) (All sections) (House and Senate)

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate, Federal Reserve) Credit Union Taxation and Expansion of Powers - Credit unions distinguishable from community banks - grown to control a significant share of the banking services market - outdated original business model - straying from founding purpose of serving individuals of modest means and with a common bond - same financial services as community banks - justification for federal tax-exempt status in exchange for serving their original mission - credit unions paying their fair share of income taxes - credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district - tax subsidy and level the playing field between credit unions and tax-paying community banks Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L) - the exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks] Credit union expansion of commercial lending powers - increasing the percentage of cap on member business lending (MBL) - loan growth at the expense of tax-paying community banks - fundamental altering the exclusive member-focused character of credit unions - condition for their original tax exemption Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts - the same Call Report filing requirements for credit unions as those imposed on community banks Support and cooperation of NCUA the cheerleader regulator of credit unions - expansion of membership proposal - weaken the common bond requirement - disregarding Congressional limits - end around Congress. Farm Credit System (FCS) - Expansionist agenda of the Farm Credit System (FCS) - the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status - tax advantages - unfair competitive advantage - follow narrow historic mission - abolish or be subject to taxation and oversight and regulation Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives Support and cooperation of cheerleader regulator of FCS lenders -Farm Credit Administration (FCA) - straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities - FCS significant systemic and taxpayer bail-out risks FCS (the only GSE) in active competition with community banks - public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks) Funding and tax benefit impact on community banks - not following its narrow historical mission - follow narrow mission or abolish FCSystem - abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by TBTFs during the financial crisis - different/modest risks posed by community banks - regulations reflecting those differences - regulatory burden on community banks - one-size-fits-all approach - disproportionate burden of banking laws and regulations on community banks Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks - unlevel playing field - a significant competitive disadvantage for community banks Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies Address excessive, redundant and costly regulations - regulatory accountability - community banks dedicating resources to promoting economic growth - steady increase in regulations over many decades - regulatory threats to community banks and their communities. The Plan for Prosperity: Basel III original intent. accurately identify Systemic Risk additional capital for small holding companies - modernizing the Federal Reserves Policy Statement relief from Securities and Exchange Commission (SEC) rules robust housing market - reform mortgage lending community bank mortgage servicing accountability in bank exams - providing a workable appeals process bank oversight and examinations - better target risk risk targeting in the Volker Rule consumer regulation and inclusive and accountable CFPB governance arbitrary disparate impact fair lending causes of action viability of mutual banks - new charter and capital options rigorous and quantitative cost-benefit analysis - justify new rules red tape in small business lending - eliminating burdensome data collection credit for low and moderate income customers and American agriculture subchapter S corporation constraints Limited Liability Corporation (LLC) option for community banks Bank Qualified (BQ) bond issuer limitations five-year loss carryback to support lending during economic downturns. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation distinguishing and appropriately regulating community banks. Legislation - H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate)

Community Bankers Association of Illinois (CBAI) 2016 Federal Policy Priorities (House and Senate) Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by TBTFs during the financial crisis - different/modest risks posed by community banks - regulations reflecting those differences - regulatory burden on community banks - one-size-fits-all approach - disproportionate burden of banking laws and regulations on community banks Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks - unlevel playing field - a significant competitive disadvantage for community banks Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies Address excessive, redundant and costly regulations - regulatory accountability - community banks dedicating resources to promoting economic growth - steady increase in regulations over many decades - regulatory threats to community banks and their communities The Plan for Prosperity: Basel III original intent. accurately identify Systemic Risk additional capital for small holding companies - modernizing the Federal Reserves Policy Statement relief from Securities and Exchange Commission (SEC) rules robust housing market - reform mortgage lending community bank mortgage servicing accountability in bank exams - providing a workable appeals process bank oversight and examinations - better target risk risk targeting in the Volker Rule consumer regulation and inclusive and accountable CFPB governance arbitrary disparate impact fair lending causes of action viability of mutual banks - new charter and capital options rigorous and quantitative cost-benefit analysis - justify new rules red tape in small business lending - eliminating burdensome data collection credit for low and moderate income customers and American agriculture subchapter S corporation constraints Limited Liability Corporation (LLC) option for community banks Bank Qualified (BQ) bond issuer limitations five-year loss carryback to support lending during economic downturns. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation distinguishing and appropriately regulating community banks. Data, Cyber and Payment Card Security (Data Security)- Wide-scale data security breaches at national retail chain stores and other entities - community banks reissuing credit and debit cards at a significant cost - community banks on the frontline of defending against cyber security threats and strong guardians of the security and confidentiality of customer information - central to maintaining public trust and the key to long-term customer retention Core data security principals - cost of data breaches borne by that party that caused the breach - all participants in the payment system (including merchants) should be subject to Gramm-Leach-Bliley Act-like data security standards - a national data security breach and notification standard should replace the current patchwork of state laws - and any new data security standards should ensure that community banks are not burdened with having to implement and comply with new regulations to achieve the same superior results they currently attain - community banks reliance on third party service providers - delicate balance between securing/sharing appropriate customer information Mortgage Lending and Housing Finance Reform - Imprudent mortgage lendings contribution to the mortgage meltdown and the financial crisis - community banks common sense relationship lending - no need for prescriptive regulations to compel doing what is right for their customers - not negatively impacting responsible community bank loan products to meet diverse needs of their customers including borrowers with special needs and circumstances, first-time homebuyers, borrowers in rural and underserved areas, and low-to-moderate income borrowers - recognize differences between the non-traditional lending practiced by community banks and the predatory lending practices of others All community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas, receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs) - an increase in the small servicer exemption, an increase in the HMDA reporting levels - a formalized safe harbor during the TRID implementation period - broad special accommodations for community banks to provide flexibility in serving the needs of their customers and communities, particularly in rural areas - and expand definition of underserved areas to include economically challenged areas Untenable long-term position of government sponsored entities (GSEs) Fannie Mae (Fannie) and Freddie Mac (Freddie) in conservatorship by the United States Treasury run by the Federal Housing Finance Agency (FHFA). In reforming to the housing GSEs, the need for the continued existence of an impartial secondary market for residential mortgages for community banks which is financially strong and reliable - the need for some level of government involvement in the secondary market to ensure the continued flow of credit and market liquidity during periods of severe economic stress - no limit in full participation by community banks or disruption in the housing market - the return of private capital to reduce the reliance on government funding - protection of taxpayers from another bailout. Community bank sale of loans through an independent entity - not competing with community banks - no appropriation of community bank customer data for the purpose of cross selling financial services - the Federal Home Loan Banks preserved as a community bank access point (but not the only access point) to the national secondary market - the pricing of the governmental guaranty being fair and equal to all participants regardless of volume of loans guaranteed - no further consolidation of the housing finance system that would result in mega banks and financial firms dominating the market. Consumer Financial Protection Bureau Reform - Consumer Financial Protection Bureau (CFPB) use of its statutory authority under the Dodd-Frank Act to exempt community banks or any products or services from the rules it writes - use of this authority to ensure community banks can continue to provide alternatives to large banks and non-banks for consumers seeking responsible financial service providers CFPB providing community banks with flexibility to meet unique needs of customers and not burden community banks with additional and unnecessary regulatory requirements to prevent them from serving their communities - no one-size-fits-all approach to CFPB regulations which harms community banks in meeting the unique needs of its local customers and communities - Community banks enduring any additional consumer regulatory burden on top of the existing burden they already face Single-Director governance of the CFPB vs. a five-member commission - residential regulators participate with the CFPB in the rule-writing process - Financial Stability Oversight Council (FSOC) power to veto CFPB rules under a practical and realistic standard - a broad definition of firms that grant credit being subject to the CFPB rules, and their supervision and examination Focus of any enhanced regulation of financial products on TBTF banks and financial firms and the unregulated shadow financial industry - efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products - holding all of the other financial service providers up to the existing high standards for compliance with consumer laws, rules and regulations as currently attained by community banks Excessive Intervention in Monetary Policy - Sustained record-low zero interest rate policy (ZIRP) engineered and implemented by the Federal Reserve System - disproportionally impact on community banks, senior citizens and savers - a significant drag on the earnings of community banks - THBF banks with non-traditional banking business lines derive a much lower percentage of their earnings from net interest margins and are not as negatively impacted - limits to what Fed monetary policy can accomplish considering major offsetting negative effects on community banks, senior citizens, and savers Legislation - H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate) H.R. 4993 - Homeowners Information Privacy Protection Act (study privacy implications of new HMDA data fields) (All sections) (House) Comment Letters - Comment Letter - Federal Financial Institutions Examination Council (FFIEC, FDIC, Federal Reserve, OCC), Uniform Interagency Consumer Compliance Rating System - FFEIC-2016-00 - undertake a new and thorough analysis of the burden, remove the opportunity for misguided interpretation, elevate the legal standard for accountability, and clarify that consumer harm can only be caused by violations of law) Miscellaneous - Regarding CFPB rulemaking - specifically regarding Qualified Mortgage (QM) exemption for small creditors and those operating in rural and underserved areas, recommendation that future rulemaking justifiably grant community banks the broad regulatory relief they deserve at the outset of rulemaking, not after a long and painful rulemaking process which only adds to the frustration and regulatory burden on community banks (CFPB)

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate) Credit Union Taxation and Expansion of Powers - Credit unions distinguishable from community banks - grown to control a significant share of the banking services market - outdated original business model - straying from founding purpose of serving individuals of modest means and with a common bond - same financial services as community banks - justification for federal tax-exempt status in exchange for serving their original mission - credit unions paying their fair share of income taxes - credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district - tax subsidy and level the playing field between credit unions and tax-paying community banks Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L) - the exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks] Credit union expansion of commercial lending powers - increasing the percentage of cap on member business lending (MBL) - loan growth at the expense of tax-paying community banks - fundamental altering the exclusive member-focused character of credit unions - condition for their original tax exemption Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts - the same Call Report filing requirements for credit unions as those imposed on community banks Support and cooperation of NCUA the cheerleader regulator of credit unions - expansion of membership proposal - weaken the common bond requirement - disregarding Congressional limits - end around Congress. Farm Credit System (FCS) - Expansionist agenda of the Farm Credit System (FCS) - the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status - tax advantages - unfair competitive advantage - follow narrow historic mission - abolish or be subject to taxation and oversight and regulation Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives Support and cooperation of cheerleader regulator of FCS lenders -Farm Credit Administration (FCA) - straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities - FCS significant systemic and taxpayer bail-out risks FCS (the only GSE) in active competition with community banks - public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks) Funding and tax benefit impact on community banks - not following its narrow historical mission - follow narrow mission or abolish FCSystem - abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by TBTFs during the financial crisis - different/modest risks posed by community banks - regulations reflecting those differences - regulatory burden on community banks - one-size-fits-all approach - disproportionate burden of banking laws and regulations on community banks Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks - unlevel playing field - a significant competitive disadvantage for community banks Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies Address excessive, redundant and costly regulations - regulatory accountability - community banks dedicating resources to promoting economic growth - steady increase in regulations over many decades - regulatory threats to community banks and their communities. The Plan for Prosperity: Basel III original intent. accurately identify Systemic Risk additional capital for small holding companies - modernizing the Federal Reserves Policy Statement relief from Securities and Exchange Commission (SEC) rules robust housing market - reform mortgage lending community bank mortgage servicing accountability in bank exams - providing a workable appeals process bank oversight and examinations - better target risk risk targeting in the Volker Rule consumer regulation and inclusive and accountable CFPB governance arbitrary disparate impact fair lending causes of action viability of mutual banks - new charter and capital options rigorous and quantitative cost-benefit analysis - justify new rules red tape in small business lending - eliminating burdensome data collection credit for low and moderate income customers and American agriculture subchapter S corporation constraints Limited Liability Corporation (LLC) option for community banks Bank Qualified (BQ) bond issuer limitations five-year loss carryback to support lending during economic downturns. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation distinguishing and appropriately regulating community banks. Legislation - H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate) Action Alerts - Action Alert - Regarding Farm Credit System (FCS) - halt FCS mission creep (Senate) Miscellaneous - Regarding the Action Alert - Farm Credit System (FCS) halt mission creep (Senate) - reinforced community bank position on this issue and corrected the inaccurate statement of CBAI position in the form letter e-mail response to the Action Alert (Senate)

Community Bankers Association of Illinois (CBAI) 2016 Federal Policy Priorities (House and Senate) Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by TBTFs during the financial crisis - different/modest risks posed by community banks - regulations reflecting those differences - regulatory burden on community banks - one-size-fits-all approach - disproportionate burden of banking laws and regulations on community banks Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks - unlevel playing field - a significant competitive disadvantage for community banks Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies Address excessive, redundant and costly regulations - regulatory accountability - community banks dedicating resources to promoting economic growth - steady increase in regulations over many decades - regulatory threats to community banks and their communities. The Plan for Prosperity: Basel III original intent. accurately identify Systemic Risk additional capital for small holding companies - modernizing the Federal Reserves Policy Statement relief from Securities and Exchange Commission (SEC) rules robust housing market - reform mortgage lending community bank mortgage servicing accountability in bank exams - providing a workable appeals process bank oversight and examinations - better target risk risk targeting in the Volker Rule consumer regulation and inclusive and accountable CFPB governance arbitrary disparate impact fair lending causes of action viability of mutual banks - new charter and capital options rigorous and quantitative cost-benefit analysis - justify new rules red tape in small business lending - eliminating burdensome data collection credit for low and moderate income customers and American agriculture subchapter S corporation constraints Limited Liability Corporation (LLC) option for community banks Bank Qualified (BQ) bond issuer limitations five-year loss carryback to support lending during economic downturns. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation distinguishing and appropriately regulating community banks. Data, Cyber and Payment Card Security (Data Security)- Wide-scale data security breaches at national retail chain stores and other entities - community banks reissuing credit and debit cards at a significant cost - community banks on the frontline of defending against cyber security threats and strong guardians of the security and confidentiality of customer information - central to maintaining public trust and the key to long-term customer retention Core data security principals - cost of data breaches borne by that party that caused the breach - all participants in the payment system (including merchants) should be subject to Gramm-Leach-Bliley Act-like data security standards - a national data security breach and notification standard should replace the current patchwork of state laws - and any new data security standards should ensure that community banks are not burdened with having to implement and comply with new regulations to achieve the same superior results they currently attain - community banks reliance on third party service providers - delicate balance between securing/sharing appropriate customer information Credit Union Taxation and Expansion of Powers - Credit unions distinguishable from community banks - grown to control a significant share of the banking services market - outdated original business model - straying from founding purpose of serving individuals of modest means and with a common bond - same financial services as community banks - justification for federal tax-exempt status in exchange for serving their original mission - credit unions paying their fair share of income taxes - credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district - tax subsidy and level the playing field between credit unions and tax-paying community banks Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L) - the exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks] Credit union expansion of commercial lending powers - increasing the percentage of cap on member business lending (MBL) - loan growth at the expense of tax-paying community banks - fundamental altering the exclusive member-focused character of credit unions - condition for their original tax exemption Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts - the same Call Report filing requirements for credit unions as those imposed on community banks Support and cooperation of NCUA the cheerleader regulator of credit unions - expansion of membership proposal - weaken the common bond requirement - disregarding Congressional limits - end around Congress. Legislation - H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate)

Community Bankers Association of Illinois (CBAI) 2016 Federal Policy Priorities (House and Senate) Too-Big-To-Fail Banks and Financial Firms, Our Financial System, Economy, and American Taxpayers - Future Bailouts - Reforming the financial system to reduce the possibility, probability, and severity of a future financial crisis - the perception and reality of too-big-to-fail (TBTF) - taxpayer bailouts of mega banks and financial firms - downsize TBTFs Growth, complexity, and interconnection of the TBTF banks - candidates for future bailouts - falling number of community banks representing less than one-fifth of banking professions assets TBTF banks and the mortgage meltdown and financial crisis - protection from massive financial destruction - taxpayer outrage at TBTFs - violations of the law (often criminal) and billions of dollars in fines, settlements and deferred prosecution agreements (conditional amnesty) TBTF effective management, supervision, discipline, and resolution - multi-trillion dollar financial assistance - rightful failure - little assistance for community banks - 500 subsequent failures and devastation U.S. Attorney General Eric Holder admission of a two-tiered system of justice, one for TBTF banks another for everyone else - board resolutions, MOUs, C&Ds, consent orders, monetary penalties, barring individuals from banking, criminal prosecution for community bank, directors, and officers - evidence of a double standard Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank) in Title II - end TBTF bailouts - Wall Street TBTF "single point of entry" (SPOE) plan for resolving failed Systemically Important Financial Institutions (SIFIs) - ensuring future bailouts for SIFIs imposing costs of bailouts on ordinary investors and taxpayers. SIFIs special long-term bonds - conversion to equity when a SIFI fails - sale of bonds to non-systemic investors - ordinary investors primary losers upon conversion into equity - insufficient to recapitalize a failed SIFI, the FDIC borrowing needed funds from the Treasury Department through the Orderly Liquidation Fund (OLF) - OLF current zero balance - backstopped by American taxpayers. Consideration of alternate resolution plans of Arthur Wilmarth, George Washington University Law School - TBTF internalize systemic risks - reduction in size and complexity - prohibition from selling special long-term bonds to ordinary individuals - SIFIs pay risk-adjusted insurance-type premiums to prefund the OLF at a level of $300 billion or more - incentive compensation rule to require SIFIs to pay at least half of total compensation to senior executives and other key employees in the form of contingent convertible bonds - expose insiders to immediate losses if SIFI fail during employment or during post-employment holding period Financial Accounting Standards Board (FASB) Current Expected Credit Loss (CECL) Model - Financial Accounting Standards Board (FASB) proposed Current Expected Credit Loss (CECL) model - implications for community banks - prepare financial institutions for a future crisis - use of forward looking information in calculating loan loss reserves The current Incurred Loss model vs. CECL - estimated day one loss and adjust estimated losses continually throughout the life of each loan - pure speculation - CECL models extensive operating system changes and cash flow modeling capabilities - cost and regulatory burden - added reserves - lower future profits, reduce capital levels, decrease community bank lending Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by TBTFs during the financial crisis - different/modest risks posed by community banks - regulations reflecting those differences - regulatory burden on community banks - one-size-fits-all approach - disproportionate burden of banking laws and regulations on community banks Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks - unlevel playing field - a significant competitive disadvantage for community banks Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies Address excessive, redundant and costly regulations - regulatory accountability - community banks dedicating resources to promoting economic growth - steady increase in regulations over many decades - regulatory threats to community banks and their communities. The Plan for Prosperity: Basel III original intent. accurately identify Systemic Risk additional capital for small holding companies - modernizing the Federal Reserves Policy Statement relief from Securities and Exchange Commission (SEC) rules robust housing market - reform mortgage lending community bank mortgage servicing accountability in bank exams - providing a workable appeals process bank oversight and examinations - better target risk risk targeting in the Volker Rule consumer regulation and inclusive and accountable CFPB governance arbitrary disparate impact fair lending causes of action viability of mutual banks - new charter and capital options rigorous and quantitative cost-benefit analysis - justify new rules red tape in small business lending - eliminating burdensome data collection credit for low and moderate income customers and American agriculture subchapter S corporation constraints Limited Liability Corporation (LLC) option for community banks Bank Qualified (BQ) bond issuer limitations five-year loss carryback to support lending during economic downturns. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation distinguishing and appropriately regulating community banks. Credit Union Taxation and Expansion of Powers - Credit unions distinguishable from community banks - grown to control a significant share of the banking services market - outdated original business model - straying from founding purpose of serving individuals of modest means and with a common bond - same financial services as community banks - justification for federal tax-exempt status in exchange for serving their original mission - credit unions paying their fair share of income taxes - credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district - tax subsidy and level the playing field between credit unions and tax-paying community banks Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L) - the exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks] Credit union expansion of commercial lending powers - increasing the percentage of cap on member business lending (MBL) - loan growth at the expense of tax-paying community banks - fundamental altering the exclusive member-focused character of credit unions - condition for their original tax exemption Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts - the same Call Report filing requirements for credit unions as those imposed on community banks Support and cooperation of NCUA the cheerleader regulator of credit unions - expansion of membership proposal - weaken the common bond requirement - disregarding Congressional limits - end around Congress. Farm Credit System (FCS) - Expansionist agenda of the Farm Credit System (FCS) - the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status - tax advantages - unfair competitive advantage - follow narrow historic mission - abolish or be subject to taxation and oversight and regulation Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives Support and cooperation of cheerleader regulator of FCS lenders -Farm Credit Administration (FCA) - straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities - FCS significant systemic and taxpayer bail-out risks FCS (the only GSE) in active competition with community banks - public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks) Funding and tax benefit impact on community banks - not following its narrow historical mission - follow narrow mission or abolish FCSystem - abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks Data, Cyber and Payment Card Security (Data Security)- Wide-scale data security breaches at national retail chain stores and other entities - community banks reissuing credit and debit cards at a significant cost - community banks on the frontline of defending against cyber security threats and strong guardians of the security and confidentiality of customer information - central to maintaining public trust and the key to long-term customer retention Core data security principals - cost of data breaches borne by that party that caused the breach - all participants in the payment system (including merchants) should be subject to Gramm-Leach-Bliley Act-like data security standards - a national data security breach and notification standard should replace the current patchwork of state laws - and any new data security standards should ensure that community banks are not burdened with having to implement and comply with new regulations to achieve the same superior results they currently attain - community banks reliance on third party service providers - delicate balance between securing/sharing appropriate customer information Mortgage Lending and Housing Finance Reform - Imprudent mortgage lendings contribution to the mortgage meltdown and the financial crisis - community banks common sense relationship lending - no need for prescriptive regulations to compel doing what is right for their customers - not negatively impacting responsible community bank loan products to meet diverse needs of their customers including borrowers with special needs and circumstances, first-time homebuyers, borrowers in rural and underserved areas, and low-to-moderate income borrowers - recognize differences between the non-traditional lending practiced by community banks and the predatory lending practices of others All community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas, receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs) - an increase in the small servicer exemption, an increase in the HMDA reporting levels - a formalized safe harbor during the TRID implementation period - broad special accommodations for community banks to provide flexibility in serving the needs of their customers and communities, particularly in rural areas - and expand definition of underserved areas to include economically challenged areas Untenable long-term position of government sponsored entities (GSEs) Fannie Mae (Fannie) and Freddie Mac (Freddie) in conservatorship by the United States Treasury run by the Federal Housing Finance Agency (FHFA). In reforming to the housing GSEs, the need for the continued existence of an impartial secondary market for residential mortgages for community banks which is financially strong and reliable - the need for some level of government involvement in the secondary market to ensure the continued flow of credit and market liquidity during periods of severe economic stress - no limit in full participation by community banks or disruption in the housing market - the return of private capital to reduce the reliance on government funding - protection of taxpayers from another bailout. Community bank sale of loans through an independent entity - not competing with community banks - no appropriation of community bank customer data for the purpose of cross selling financial services - the Federal Home Loan Banks preserved as a community bank access point (but not the only access point) to the national secondary market - the pricing of the governmental guaranty being fair and equal to all participants regardless of volume of loans guaranteed - no further consolidation of the housing finance system that would result in mega banks and financial firms dominating the market. Consumer Financial Protection Bureau Reform - Consumer Financial Protection Bureau (CFPB) use of its statutory authority under the Dodd-Frank Act to exempt community banks or any products or services from the rules it writes - use of this authority to ensure community banks can continue to provide alternatives to large banks and non-banks for consumers seeking responsible financial service providers CFPB providing community banks with flexibility to meet unique needs of customers and not burden community banks with additional and unnecessary regulatory requirements to prevent them from serving their communities - no one-size-fits-all approach to CFPB regulations which harms community banks in meeting the unique needs of its local customers and communities - Community banks enduring any additional consumer regulatory burden on top of the existing burden they already face Single-Director governance of the CFPB vs. a five-member commission - residential regulators participate with the CFPB in the rule-writing process - Financial Stability Oversight Council (FSOC) power to veto CFPB rules under a practical and realistic standard - a broad definition of firms that grant credit being subject to the CFPB rules, and their supervision and examination Focus of any enhanced regulation of financial products on TBTF banks and financial firms and the unregulated shadow financial industry - efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products - holding all of the other financial service providers up to the existing high standards for compliance with consumer laws, rules and regulations as currently attained by community banks De Novo Community Bank Formation and the Dual Banking System/Charter Choice - Newly chartered (de novo) community banks importance in maintaining a strong, growing, evolving and vibrant banking profession - FDICs inhibiting de novo community bank formation during the financial crisis, FDICs indication of a change in policy direction by rescinding its Financial Institution Letter (FIL) 50-2009, Enhanced Supervisory Procedures for Newly Insured FDIC-Supervised Depository Institutions The importance of the dual banking system where chartering and supervision is divided between the federal government and the states - community banks choice of charters that best fits their business model - multi-agency (state and federal) regulators and charter choice providing necessary checks and balances on the power of the regulators, as well as improved rulemaking, the benefit of each agencies expertise and experience is brought to bear on complex and controversial issues Federal Home Loan Bank System - Federal Home Loan Banks (FHLBs) strong partnership with community banks - providing short-term liquidity, long-term funding and other financial products that serve the needs of all member-owners - providing lendable funds for the local communities - regional structure, special functions and purposes of the FHLBs recognized and maintained by the Federal Housing Finance Agency (FHFA). FHFAs proposed rulemaking to revise FHLB membership eligibility requirements - negative impact on the FHLB System and its members - precedent set to terminate through rulemaking FHLB membership and the threat to revisit the broader membership issue in the future - contrary to the will of Congress FHLB System position as a healthy, stable and reliable source of funding for its members - not as the sole aggregator or securitizer of residential mortgages for community banks - FHFAs imposition of an ongoing housing mission asset test on community financial institutions Excessive Intervention in Monetary Policy - Sustained record-low zero interest rate policy (ZIRP) engineered and implemented by the Federal Reserve System - disproportionally impact on community banks, senior citizens and savers - a significant drag on the earnings of community banks - THBF banks with non-traditional banking business lines derive a much lower percentage of their earnings from net interest margins and are not as negatively impacted - limits to what Fed monetary policy can accomplish considering major offsetting negative effects on community banks, senior citizens, and savers Legislation - H.R. 4500 - Community Bank Reporting Relief Act (amends the FDIC Act to permit reduced reporting requirements (Call Reports) for the first and third quarters for highly-rated well-capitalized banks (All Sections) (House) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate) H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate) H.R. 4993 - Homeowners Information Privacy Protection Act (study privacy implications of new HMDA data fields) (All sections) (House) H.R. 4950 - Small Financial Institution Advisory Committee Act of 2016 (creates a Treasury Department community bank advisory committee) (All sections) (House) Comment Letters - Comment Letter - Federal Housing Finance Agency (FHFA , Proposed Rule on Acquired Member Assets - RIN 2590-AA69 - revise to better allow for appropriate product innovation and development) Comment Letter - Federal Financial Institutions Examination Council (FFIEC - FDIC, Federal Reserve, OCC), Uniform Interagency Consumer Compliance Rating System - FFEIC-2016-00 - undertake a new and thorough analysis of the burden, remove the opportunity for misguided interpretation, elevate the legal standard for accountability, and clarify that consumer harm can only be caused by violations of law) Action Alerts - Action Alert - Regarding Farm Credit System (FCS) - halt FCS mission creep (Senate) Miscellaneous - Regarding CFPB rulemaking - specifically regarding Qualified Mortgage (QM) exemption for small creditors and those operating in rural and underserved areas, recommendation that future rulemaking justifiably grant community banks the broad regulatory relief they deserve at the outset of rulemaking, not after a long and painful rulemaking process which only adds to the frustration and regulatory burden on community banks (CFPB) Regarding the Action Alert - Farm Credit System (FCS) halt mission creep (Senate) - reinforced community bank position on this issue and corrected the inaccurate statement of CBAI position in the form letter e-mail response to the Action Alert (Senate) Regarding Member Letter regarding High Volatility Commercial Real Estate (HVCRE) - Responded to member request for position on this issue (House)

Community Bankers Association of Illinois (CBAI) 2016 Federal Policy Priorities (House and Senate) Too-Big-To-Fail Banks and Financial Firms, Our Financial System, Economy, and American Taxpayers - Future Bailouts - Reforming the financial system to reduce the possibility, probability, and severity of a future financial crisis - the perception and reality of too-big-to-fail (TBTF) - taxpayer bailouts of mega banks and financial firms - downsize TBTFs Growth, complexity, and interconnection of the TBTF banks - candidates for future bailouts - falling number of community banks representing less than one-fifth of banking professions assets TBTF banks and the mortgage meltdown and financial crisis - protection from massive financial destruction - taxpayer outrage at TBTFs - violations of the law (often criminal) and billions of dollars in fines, settlements and deferred prosecution agreements (conditional amnesty) TBTF effective management, supervision, discipline, and resolution - multi-trillion dollar financial assistance - rightful failure - little assistance for community banks - 500 subsequent failures and devastation U.S. Attorney General Eric Holder admission of a two-tiered system of justice, one for TBTF banks another for everyone else - board resolutions, MOUs, C&Ds, consent orders, monetary penalties, barring individuals from banking, criminal prosecution for community bank, directors, and officers - evidence of a double standard Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank) in Title II - end TBTF bailouts - Wall Street TBTF "single point of entry" (SPOE) plan for resolving failed Systemically Important Financial Institutions (SIFIs) - ensuring future bailouts for SIFIs imposing costs of bailouts on ordinary investors and taxpayers. SIFIs special long-term bonds - conversion to equity when a SIFI fails - sale of bonds to non-systemic investors - ordinary investors primary losers upon conversion into equity - insufficient to recapitalize a failed SIFI, the FDIC borrowing needed funds from the Treasury Department through the Orderly Liquidation Fund (OLF) - OLF current zero balance - backstopped by American taxpayers. Consideration of alternate resolution plans of Arthur Wilmarth, George Washington University Law School - TBTF internalize systemic risks - reduction in size and complexity - prohibition from selling special long-term bonds to ordinary individuals - SIFIs pay risk-adjusted insurance-type premiums to prefund the OLF at a level of $300 billion or more - incentive compensation rule to require SIFIs to pay at least half of total compensation to senior executives and other key employees in the form of contingent convertible bonds - expose insiders to immediate losses if SIFI fail during employment or during post-employment holding period Financial Accounting Standards Board (FASB) Current Expected Credit Loss (CECL) Model - Financial Accounting Standards Board (FASB) proposed Current Expected Credit Loss (CECL) model - implications for community banks - prepare financial institutions for a future crisis - use of forward looking information in calculating loan loss reserves The current Incurred Loss model vs. CECL - estimated day one loss and adjust estimated losses continually throughout the life of each loan - pure speculation - CECL models extensive operating system changes and cash flow modeling capabilities - cost and regulatory burden - added reserves - lower future profits, reduce capital levels, decrease community bank lending Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by TBTFs during the financial crisis - different/modest risks posed by community banks - regulations reflecting those differences - regulatory burden on community banks - one-size-fits-all approach - disproportionate burden of banking laws and regulations on community banks Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks - unlevel playing field - a significant competitive disadvantage for community banks Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies Address excessive, redundant and costly regulations - regulatory accountability - community banks dedicating resources to promoting economic growth - steady increase in regulations over many decades - regulatory threats to community banks and their communities. The Plan for Prosperity: Basel III original intent. accurately identify Systemic Risk additional capital for small holding companies - modernizing the Federal Reserves Policy Statement relief from Securities and Exchange Commission (SEC) rules robust housing market - reform mortgage lending community bank mortgage servicing accountability in bank exams - providing a workable appeals process bank oversight and examinations - better target risk risk targeting in the Volker Rule consumer regulation and inclusive and accountable CFPB governance arbitrary disparate impact fair lending causes of action viability of mutual banks - new charter and capital options rigorous and quantitative cost-benefit analysis - justify new rules red tape in small business lending - eliminating burdensome data collection credit for low and moderate income customers and American agriculture subchapter S corporation constraints Limited Liability Corporation (LLC) option for community banks Bank Qualified (BQ) bond issuer limitations five-year loss carryback to support lending during economic downturns. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation distinguishing and appropriately regulating community banks. Credit Union Taxation and Expansion of Powers - Credit unions distinguishable from community banks - grown to control a significant share of the banking services market - outdated original business model - straying from founding purpose of serving individuals of modest means and with a common bond - same financial services as community banks - justification for federal tax-exempt status in exchange for serving their original mission - credit unions paying their fair share of income taxes - credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district - tax subsidy and level the playing field between credit unions and tax-paying community banks Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L) - the exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks] Credit union expansion of commercial lending powers - increasing the percentage of cap on member business lending (MBL) - loan growth at the expense of tax-paying community banks - fundamental altering the exclusive member-focused character of credit unions - condition for their original tax exemption Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts - the same Call Report filing requirements for credit unions as those imposed on community banks Support and cooperation of NCUA the cheerleader regulator of credit unions - expansion of membership proposal - weaken the common bond requirement - disregarding Congressional limits - end around Congress. Farm Credit System (FCS) - Expansionist agenda of the Farm Credit System (FCS) - the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status - tax advantages - unfair competitive advantage - follow narrow historic mission - abolish or be subject to taxation and oversight and regulation Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives Support and cooperation of cheerleader regulator of FCS lenders -Farm Credit Administration (FCA) - straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities - FCS significant systemic and taxpayer bail-out risks FCS (the only GSE) in active competition with community banks - public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks) Funding and tax benefit impact on community banks - not following its narrow historical mission - follow narrow mission or abolish FCSystem - abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks Data, Cyber and Payment Card Security (Data Security)- Wide-scale data security breaches at national retail chain stores and other entities - community banks reissuing credit and debit cards at a significant cost - community banks on the frontline of defending against cyber security threats and strong guardians of the security and confidentiality of customer information - central to maintaining public trust and the key to long-term customer retention Core data security principals - cost of data breaches borne by that party that caused the breach - all participants in the payment system (including merchants) should be subject to Gramm-Leach-Bliley Act-like data security standards - a national data security breach and notification standard should replace the current patchwork of state laws - and any new data security standards should ensure that community banks are not burdened with having to implement and comply with new regulations to achieve the same superior results they currently attain - community banks reliance on third party service providers - delicate balance between securing/sharing appropriate customer information Mortgage Lending and Housing Finance Reform - Imprudent mortgage lendings contribution to the mortgage meltdown and the financial crisis - community banks common sense relationship lending - no need for prescriptive regulations to compel doing what is right for their customers - not negatively impacting responsible community bank loan products to meet diverse needs of their customers including borrowers with special needs and circumstances, first-time homebuyers, borrowers in rural and underserved areas, and low-to-moderate income borrowers - recognize differences between the non-traditional lending practiced by community banks and the predatory lending practices of others All community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas, receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs) - an increase in the small servicer exemption, an increase in the HMDA reporting levels - a formalized safe harbor during the TRID implementation period - broad special accommodations for community banks to provide flexibility in serving the needs of their customers and communities, particularly in rural areas - and expand definition of underserved areas to include economically challenged areas Untenable long-term position of government sponsored entities (GSEs) Fannie Mae (Fannie) and Freddie Mac (Freddie) in conservatorship by the United States Treasury run by the Federal Housing Finance Agency (FHFA). In reforming to the housing GSEs, the need for the continued existence of an impartial secondary market for residential mortgages for community banks which is financially strong and reliable - the need for some level of government involvement in the secondary market to ensure the continued flow of credit and market liquidity during periods of severe economic stress - no limit in full participation by community banks or disruption in the housing market - the return of private capital to reduce the reliance on government funding - protection of taxpayers from another bailout. Community bank sale of loans through an independent entity - not competing with community banks - no appropriation of community bank customer data for the purpose of cross selling financial services - the Federal Home Loan Banks preserved as a community bank access point (but not the only access point) to the national secondary market - the pricing of the governmental guaranty being fair and equal to all participants regardless of volume of loans guaranteed - no further consolidation of the housing finance system that would result in mega banks and financial firms dominating the market. Consumer Financial Protection Bureau Reform - Consumer Financial Protection Bureau (CFPB) use of its statutory authority under the Dodd-Frank Act to exempt community banks or any products or services from the rules it writes - use of this authority to ensure community banks can continue to provide alternatives to large banks and non-banks for consumers seeking responsible financial service providers CFPB providing community banks with flexibility to meet unique needs of customers and not burden community banks with additional and unnecessary regulatory requirements to prevent them from serving their communities - no one-size-fits-all approach to CFPB regulations which harms community banks in meeting the unique needs of its local customers and communities - Community banks enduring any additional consumer regulatory burden on top of the existing burden they already face Single-Director governance of the CFPB vs. a five-member commission - residential regulators participate with the CFPB in the rule-writing process - Financial Stability Oversight Council (FSOC) power to veto CFPB rules under a practical and realistic standard - a broad definition of firms that grant credit being subject to the CFPB rules, and their supervision and examination Focus of any enhanced regulation of financial products on TBTF banks and financial firms and the unregulated shadow financial industry - efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products - holding all of the other financial service providers up to the existing high standards for compliance with consumer laws, rules and regulations as currently attained by community banks De Novo Community Bank Formation and the Dual Banking System/Charter Choice - Newly chartered (de novo) community banks importance in maintaining a strong, growing, evolving and vibrant banking profession - FDICs inhibiting de novo community bank formation during the financial crisis, FDICs indication of a change in policy direction by rescinding its Financial Institution Letter (FIL) 50-2009, Enhanced Supervisory Procedures for Newly Insured FDIC-Supervised Depository Institutions The importance of the dual banking system where chartering and supervision is divided between the federal government and the states - community banks choice of charters that best fits their business model - multi-agency (state and federal) regulators and charter choice providing necessary checks and balances on the power of the regulators, as well as improved rulemaking, the benefit of each agencies expertise and experience is brought to bear on complex and controversial issues Federal Home Loan Bank System - Federal Home Loan Banks (FHLBs) strong partnership with community banks - providing short-term liquidity, long-term funding and other financial products that serve the needs of all member-owners - providing lendable funds for the local communities - regional structure, special functions and purposes of the FHLBs recognized and maintained by the Federal Housing Finance Agency (FHFA). FHFAs proposed rulemaking to revise FHLB membership eligibility requirements - negative impact on the FHLB System and its members - precedent set to terminate through rulemaking FHLB membership and the threat to revisit the broader membership issue in the future - contrary to the will of Congress FHLB System position as a healthy, stable and reliable source of funding for its members - not as the sole aggregator or securitizer of residential mortgages for community banks - FHFAs imposition of an ongoing housing mission asset test on community financial institutions Excessive Intervention in Monetary Policy - Sustained record-low zero interest rate policy (ZIRP) engineered and implemented by the Federal Reserve System - disproportionally impact on community banks, senior citizens and savers - a significant drag on the earnings of community banks - THBF banks with non-traditional banking business lines derive a much lower percentage of their earnings from net interest margins and are not as negatively impacted - limits to what Fed monetary policy can accomplish considering major offsetting negative effects on community banks, senior citizens, and savers Legislation - H.R. 4500 - Community Bank Reporting Relief Act (amends the FDIC Act to permit reduced reporting requirements (Call Reports) for the first and third quarters for highly-rated well-capitalized banks (All Sections) (House) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate) H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate) H.R. 4993 - Homeowners Information Privacy Protection Act (study privacy implications of new HMDA data fields) (All sections) (House) H.R. 4950 - Small Financial Institution Advisory Committee Act of 2016 (creates a Treasury Department community bank advisory committee) (All sections) (House) Comment Letters - Comment Letter - Federal Housing Finance Agency (FHFA), Proposed Rule on Acquired Member Assets - RIN 2590-AA69 - revise to better allow for appropriate product innovation and development) Comment Letter - Federal Financial Institutions Examination Council (FFIEC, FDIC, Federal Reserve, OCC), Uniform Interagency Consumer Compliance Rating System - FFEIC-2016-00 - undertake a new and thorough analysis of the burden, remove the opportunity for misguided interpretation, elevate the legal standard for accountability, and clarify that consumer harm can only be caused by violations of law) Action Alerts - Action Alert - Regarding Farm Credit System (FCS) - halt FCS mission creep (Senate) Miscellaneous - Regarding CFPB rulemaking - specifically regarding Qualified Mortgage (QM) exemption for small creditors and those operating in rural and underserved areas, recommendation that future rulemaking justifiably grant community banks the broad regulatory relief they deserve at the outset of rulemaking, not after a long and painful rulemaking process which only adds to the frustration and regulatory burden on community banks (CFPB) Regarding the Action Alert - Farm Credit System (FCS) halt mission creep (Senate) - reinforced community bank position on this issue and corrected the inaccurate statement of CBAI position in the form letter e-mail response to the Action Alert (Senate) Regarding Member Letter regarding High Volatility Commercial Real Estate (HVCRE) - Responded to member request for position on this issue (House)

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate, FDIC, OCC, CFPB) Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by Wall Street mega banks during the financial crisis. The different/modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a one-size-fits-all approach. Disproportionate burden of banking laws and regulations on community banks. Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks. Unlevel playing field and a significant competitive disadvantage for community banks. Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies. Excessive, redundant and costly regulations. Regulatory accountability. Community banks dedicating resources to promoting economic growth. Steady increase in regulations over many decades. Regulatory threats to community banks and their communities. The Plan for Prosperity regarding: Basel III original intent. additional capital for small holding companies - modernize the Federal Reserves Policy Statement. Securities and Exchange Commission rules. reforming mortgage lending. accountability in bank exams by providing an appeals process. bank oversight and examinations - targeting risks. annual requirement for redundant privacy notices. consumer regulation - inclusive and accountable CFPB governance. arbitrary disparate impact fair lending causes of action. viability of mutual banks with new charter options. cost-benefit analysis to justify new rules. red tape in small business lending - burdensome data collection. community bank mortgage servicing. Treasury Assistant Secretary for Community Banks. subchapter S constraints. five-year loss carryback - support for lending during economic downturns. risk targeting in the Volcker Rule. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks. Credit Union Taxation and Expansion of Powers - Credit unions now indistinguishable from community banks, grown to control a significant share of the banking services market. Original business model now outdated. Credit unions strayed from founding purpose of serving individuals of modest means and with a common bond. Same financial services as community banks. Federal tax-exempt status, in exchange for serving their original mission is no longer justified. Credit unions paying their fair share of income taxes. Credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district . Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L). The exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks]. The Office of Management and Budget tax expenditure analysis - tax-exemption for credit unions result in loss of tax revenues of $9.46 billion over fiscal years 2014-2018. Credit union expansion of commercial lending powers - increasing the percentage of cap on member business lending (MBL). Loan growth at the expense of tax-paying community banks. Fundamental altering the exclusive member-focused character of credit unions - a condition for their original tax exemption. Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts. The same Call Report filing requirements for credit unions as those imposed on community banks. Tax subsidy and level the playing field between credit unions and tax-paying community banks. Farm Credit System - Expansionist agenda of the Farm Credit System (FCS). FCS almost the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status. Tax advantages - unfair competitive advantage. Follow narrow historic mission - abolish or be subject to taxation and oversight and regulation. Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives. Support and cooperation of Farm Credit Administration (FCA) - FCS straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities. FCS significant systemic and taxpayer bail-out risks. The FCS (only GSE) in active competition with community banks. Public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks). Funding and tax benefits impact on community banks. FCS not following its narrow historical mission. Follow narrow mission or abolish System. Abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity. FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight. Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks. Enhanced Cyber, Data and Payment Card Security - Establish a federal data security standard and notice requirement for all entities that store consumer data comparable to the Gramm-Leach-Bliley Act (GLBA) standards that apply to community banks. Shifting the liability for all costs associated with the data breach - including fraud losses and the cost of card reissuance - to the party that caused the breach. Legislation - H.R. 4500 - Community Bank Reporting Relief Act (amends the FDIC Act to permit reduced reporting requirements (Call Reports) for the first and third quarters for highly-rated well-capitalized banks (All Sections) (House) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate, FDIC, OCC, CFPB) H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate, FDIC, OCC, CFPB) H.R. 2205 and S. 961 - Data Security Act of 2015 (data breach and security, notifications, safeguards, GLBA compliance procedures) (all sections) (House and Senate, FDIC, OCC, CFPB) Comment Letters - Comment letter - Financial Crimes Enforcement Network (FinCEN), (Regulatory Impact Assessment & Initial Flexibility Analysis - Customer Due Diligence Requirements for Financial Institutions, RIN 1506-AB25 - breakeven analysis of new regulations, clarify and strengthen customer due diligence (CDD) requirements regarding beneficial owners of legal entity customers) (House) Comment Letter - National Credit Union Associations (NCUA) (proposed expansion of field of membership in their Notice of Proposed Rulemaking - Field of Membership - RIN 3133-AE31) Comment Letter - Federal Reserve, FDIC, OCC (Economic Growth and Recovery Paperwork Reduction Act (EGRPRA decennial regulatory review process) - specifically Bank Secrecy Act (BSA)/Anti-Money Laundering (AML), Community Reinvestment Act (CRA), repeat examination findings, brokered deposits (Call Report and waivers), and FR Y-8 reporting (as contained in CBAI Comment Letters - Docket ID FFIEC-2014-0001 and Docket No. R-1510) (House) Action Alerts - Action Alert - National Credit Union Associations (NCUA) proposed expansion of field of membership in their Notice of Proposed Rulemaking - Field of Membership - RIN 3133-AE31 (NCUA, House and Senate) Miscellaneous - Regarding the Financial Accounting Standards Board (FASB) Current Expected Credit Loss (CECL) model - specifically the proposed new methodology impact on community banks, day-one estimates of losses, estimated loss adjustments throughout the life of the loan, operating system changes, recognition of losses sooner in the life cycle of a loan, and countercyclical additions to the Allowance for Loan and Lease Losses (House and Senate, FDIC, OCC, CFPB) Regarding the Financial Accounting Standards Board (FASB) Current Expected Credit Loss (CECL) model - specifically U.S. House of Representatives Tipton-Murphy member letter to FASB (House)

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate, FDIC, OCC, CFPB) Farm Credit System - Expansionist agenda of the Farm Credit System (FCS). FCS almost the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status. Tax advantages - unfair competitive advantage. Follow narrow historic mission - abolish or be subject to taxation and oversight and regulation. Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives. Support and cooperation of Farm Credit Administration (FCA) - FCS straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities. FCS significant systemic and taxpayer bail-out risks. The FCS (only GSE) in active competition with community banks. Public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks). Funding and tax benefits impact on community banks. FCS not following its narrow historical mission. Follow narrow mission or abolish System. Abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity. FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight. Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks.

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate, FDIC, OCC, CFPB) Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by Wall Street mega banks during the financial crisis. The different/modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a one-size-fits-all approach. Disproportionate burden of banking laws and regulations on community banks. Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks. Unlevel playing field and a significant competitive disadvantage for community banks. Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies. Excessive, redundant and costly regulations. Regulatory accountability. Community banks dedicating resources to promoting economic growth. Steady increase in regulations over many decades. Regulatory threats to community banks and their communities. The Plan for Prosperity regarding: Basel III original intent. additional capital for small holding companies - modernize the Federal Reserves Policy Statement. Securities and Exchange Commission rules. reforming mortgage lending. accountability in bank exams by providing an appeals process. bank oversight and examinations - targeting risks. annual requirement for redundant privacy notices. consumer regulation - inclusive and accountable CFPB governance. arbitrary disparate impact fair lending causes of action. viability of mutual banks with new charter options. cost-benefit analysis to justify new rules. red tape in small business lending - burdensome data collection. community bank mortgage servicing. Treasury Assistant Secretary for Community Banks. subchapter S constraints. five-year loss carryback - support for lending during economic downturns. risk targeting in the Volcker Rule. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks. Enhanced Cyber, Data and Payment Card Security - Establish a federal data security standard and notice requirement for all entities that store consumer data comparable to the Gramm-Leach-Bliley Act (GLBA) standards that apply to community banks. Shifting the liability for all costs associated with the data breach - including fraud losses and the cost of card reissuance - to the party that caused the breach. Legislation - H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate, FDIC, OCC, CFPB) H.R. 2205 and S. 961 - Data Security Act of 2015 (data breach and security, notifications, safeguards, GLBA compliance procedures) (All sections) (House and Senate, FDIC, OCC, CFPB) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate, FDIC, OCC, CFPB)

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate, FDIC, OCC, CFPB) Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by Wall Street mega banks during the financial crisis. The different/modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a one-size-fits-all approach. Disproportionate burden of banking laws and regulations on community banks. Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks. Unlevel playing field and a significant competitive disadvantage for community banks. Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies. Excessive, redundant and costly regulations. Regulatory accountability. Community banks dedicating resources to promoting economic growth. Steady increase in regulations over many decades. Regulatory threats to community banks and their communities. The Plan for Prosperity regarding: Basel III original intent. additional capital for small holding companies - modernize the Federal Reserves Policy Statement. Securities and Exchange Commission rules. reforming mortgage lending. accountability in bank exams by providing an appeals process. bank oversight and examinations - targeting risks. annual requirement for redundant privacy notices. consumer regulation - inclusive and accountable CFPB governance. arbitrary disparate impact fair lending causes of action. viability of mutual banks with new charter options. cost-benefit analysis to justify new rules. red tape in small business lending - burdensome data collection. community bank mortgage servicing. Treasury Assistant Secretary for Community Banks. subchapter S constraints. five-year loss carryback - support for lending during economic downturns. risk targeting in the Volcker Rule. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks. Credit Union Taxation and Expansion of Powers - Credit unions now indistinguishable from community banks, grown to control a significant share of the banking services market. Original business model now outdated. Credit unions strayed from founding purpose of serving individuals of modest means and with a common bond. Same financial services as community banks. Federal tax-exempt status, in exchange for serving their original mission is no longer justified. Credit unions paying their fair share of income taxes. Credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district . Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L). The exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks]. The Office of Management and Budget tax expenditure analysis - tax-exemption for credit unions result in loss of tax revenues of $9.46 billion over fiscal years 2014-2018. Credit union expansion of commercial lending powers - increasing the percentage of cap on member business lending (MBL). Loan growth at the expense of tax-paying community banks. Fundamental altering the exclusive member-focused character of credit unions - a condition for their original tax exemption. Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts. The same Call Report filing requirements for credit unions as those imposed on community banks. Tax subsidy and level the playing field between credit unions and tax-paying community banks. Farm Credit System - Expansionist agenda of the Farm Credit System (FCS). FCS almost the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status. Tax advantages - unfair competitive advantage. Follow narrow historic mission - abolish or be subject to taxation and oversight and regulation. Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives. Support and cooperation of Farm Credit Administration (FCA) - FCS straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities. FCS significant systemic and taxpayer bail-out risks. The FCS (only GSE) in active competition with community banks. Public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks). Funding and tax benefits impact on community banks. FCS not following its narrow historical mission. Follow narrow mission or abolish System. Abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity. FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight. Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks. Enhanced Cyber, Data and Payment Card Security - Establish a federal data security standard and notice requirement for all entities that store consumer data comparable to the Gramm-Leach-Bliley Act (GLBA) standards that apply to community banks. Shifting the liability for all costs associated with the data breach - including fraud losses and the cost of card reissuance - to the party that caused the breach. Legislation - H.R. 4500 - Community Bank Reporting Relief Act (amends the FDIC Act to permit reduced reporting requirements (Call Reports) for the first and third quarters for highly-rated well-capitalized banks (All Sections) (House) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate, FDIC, OCC, CFPB) H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate, FDIC, OCC, CFPB) H.R. 2205 and S. 961 - Data Security Act of 2015 (data breach and security, notifications, safeguards, GLBA compliance procedures) (all sections) (House and Senate, FDIC, OCC, CFPB) Comment Letters - Comment letter - Financial Crimes Enforcement Network (FinCEN), (Regulatory Impact Assessment & Initial Flexibility Analysis - Customer Due Diligence Requirements for Financial Institutions, RIN 1506-AB25 - breakeven analysis of new regulations, clarify and strengthen customer due diligence (CDD) requirements regarding beneficial owners of legal entity customers) (House) Comment Letter - National Credit Union Associations (NCUA) (proposed expansion of field of membership in their Notice of Proposed Rulemaking - Field of Membership - RIN 3133-AE31) Comment Letter - Federal Reserve, FDIC, OCC (Economic Growth and Recovery Paperwork Reduction Act (EGRPRA decennial regulatory review process) - specifically Bank Secrecy Act (BSA)/Anti-Money Laundering (AML), Community Reinvestment Act (CRA), repeat examination findings, brokered deposits (Call Report and waivers), and FR Y-8 reporting (as contained in CBAI Comment Letters - Docket ID FFIEC-2014-0001 and Docket No. R-1510) (House) Action Alerts - Action Alert - National Credit Union Associations (NCUA) proposed expansion of field of membership in their Notice of Proposed Rulemaking - Field of Membership - RIN 3133-AE31 (NCUA, House and Senate) Miscellaneous - Regarding the Financial Accounting Standards Board (FASB) Current Expected Credit Loss (CECL) model - specifically the proposed new methodology impact on community banks, day-one estimates of losses, estimated loss adjustments throughout the life of the loan, operating system changes, recognition of losses sooner in the life cycle of a loan, and countercyclical additions to the Allowance for Loan and Lease Losses (House and Senate, FDIC, OCC, CFPB) Regarding the Financial Accounting Standards Board (FASB) Current Expected Credit Loss (CECL) model - specifically U.S. House of Representatives Tipton-Murphy member letter to FASB (House)

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate, FDIC, OCC, CFPB) Credit Union Taxation and Expansion of Powers - Credit unions now indistinguishable from community banks, grown to control a significant share of the banking services market. Original business model now outdated. Credit unions strayed from founding purpose of serving individuals of modest means and with a common bond. Same financial services as community banks. Federal tax-exempt status, in exchange for serving their original mission is no longer justified. Credit unions paying their fair share of income taxes. Credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district. Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L). The exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks]. The Office of Management and Budget tax expenditure analysis - tax-exemption for credit unions result in loss of tax revenues of $9.46 billion over fiscal years 2014-2018. Credit union expansion of commercial lending powers - increasing the percentage of assets cap on member business lending (MBL). Loan growth at the expense of tax-paying community banks. Fundamental altering the exclusive member-focused character of credit unions - a condition for their original tax exemption. Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts. The same Call Report filing requirements for credit unions as those imposed on community banks. Tax subsidy and level the playing field between credit unions and tax-paying community banks. Farm Credit System - Expansionist agenda of the Farm Credit System (FCS). FCS almost the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status. Tax advantages - unfair competitive advantage. Follow narrow historic mission - abolish or be subject to taxation and oversight and regulation. Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives. Support and cooperation of Farm Credit Administration (FCA) - FCS straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities. FCS significant systemic and taxpayer bail-out risks. The FCS (only GSE) in active competition with community banks. Public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks). Funding and tax benefits impact on community banks. FCS not following its narrow historical mission. Follow narrow mission or abolish System. Abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity. FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight. Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks. Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by Wall Street mega banks during the financial crisis. The different/modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a one-size-fits-all approach. Disproportionate burden of banking laws and regulations on community banks. Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks. Unlevel playing field and a significant competitive disadvantage for community banks. Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies. Excessive, redundant and costly regulations. Regulatory accountability. Community banks dedicating resources to promoting economic growth. Steady increase in regulations over many decades. Regulatory threats to community banks and their communities. The Plan for Prosperity regarding: Basel III original intent. additional capital for small holding companies - modernize the Federal Reserves Policy Statement. Securities and Exchange Commission rules. reforming mortgage lending. accountability in bank exams by providing an appeals process. bank oversight and examinations - targeting risks. annual requirement for redundant privacy notices. consumer regulation - inclusive and accountable CFPB governance. arbitrary disparate impact fair lending causes of action. viability of mutual banks with new charter options. cost-benefit analysis to justify new rules. red tape in small business lending - burdensome data collection. community bank mortgage servicing. Treasury Assistant Secretary for Community Banks. subchapter S constraints. five-year loss carryback - support for lending during economic downturns. risk targeting in the Volcker Rule. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks. Legislation - H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate, FDIC, OCC, CFPB) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate, FDIC, OCC, CFPB) Comment Letters - Comment Letter - National Credit Union Associations (NCUA) (proposed expansion of field of membership in their Notice of Proposed Rulemaking - Field of Membership - RIN 3133-AE31) Action Alerts - Action Alert - National Credit Union Associations (NCUA) proposed expansion of field of membership in their Notice of Proposed Rulemaking - Field of Membership - RIN 3133-AE31 (NCUA, House and Senate)

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate, FDIC, OCC) Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by Wall Street mega banks during the financial crisis. The different/modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a one-size-fits-all approach. Disproportionate burden of banking laws and regulations on community banks. Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks. Unlevel playing field and a significant competitive disadvantage for community banks. Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies. Excessive, redundant and costly regulations. Regulatory accountability. Community banks dedicating resources to promoting economic growth. Steady increase in regulations over many decades. Regulatory threats to community banks and their communities. The Plan for Prosperity regarding: Basel III original intent. additional capital for small holding companies - modernize the Federal Reserves Policy Statement. Securities and Exchange Commission rules. reforming mortgage lending. accountability in bank exams by providing an appeals process. bank oversight and examinations - targeting risks. annual requirement for redundant privacy notices. consumer regulation - inclusive and accountable CFPB governance. arbitrary disparate impact fair lending causes of action. viability of mutual banks with new charter options. cost-benefit analysis to justify new rules. red tape in small business lending - burdensome data collection. community bank mortgage servicing. Treasury Assistant Secretary for Community Banks. subchapter S constraints. five-year loss carryback - support for lending during economic downturns. risk targeting in the Volcker Rule. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks. Legislation - S. 1484 - Financial Regulatory Improvement Act of 2015 (bank regulatory relief) (Title I - all sections) (House and Senate, FDIC, OCC) H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate, FDIC, OCC) H.R. 2205 and S. 961 - Data Security Act of 2015 (data breach and security, notifications, safeguards, GLBA compliance procedures) (All sections) (House and Senate, FDIC, OCC) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate, FDIC, OCC)

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate, FDIC, OCC) Too-to-Fail - Reform the financial system. The severity of a future financial crisis. The perception and reality of too-big-to-fail. Taxpayer bailouts of mega banks and financial firms. Mega bank size, complexity and interconnectedness, and candidacy for future bailouts. The number of community banks falling by more than half (currently 6,200 institutions) and now represent less than one-fifth of banking professions assets. Causes of the mortgage meltdown and financial crisis. Protection of the nation and the banking profession from a repeat of massive financial destruction. Taxpayer-funded bailouts of too-big-to-fail banks and financial firms and their numerous violations of the law, often criminal violations. Effective management, supervision, discipline, or resolution of too-big-to-fail banks and financial firms. Mega bank multi-trillion dollars financial assistance versus community banks assistance and more than 500 failed community banks. Downsizing too-big-to-fail banks and financial firms. The fundamental American constitutional right of equal justice under the law applicability when it comes to the mega banks. The U.S. two-tiered system of justice - too-big-to-fail banks and financial firms and everyone else. The Department of Justice (DOJ) - laggard in prosecuting crimes stemming from the financial crisis. Banking regulators and the DOJ aggressively pursuing actions against community banks, their directors, and officers with board resolutions, MOUs, C&Ds, consent orders, monetary penalties, barring individuals from banking, criminal prosecution, and other actions. No mandatory Prompt Corrective Action (PCA) capital enforcement orders against any bank larger than $30 billion in assets, yet 1,400 PCAs against community banks. Evidence of a clear double standard. Opponents of downsizing the mega banks (include their paid association cheerleaders) consistently blocking meaningful reforms and obfuscating the issue of too-big-to-fail for the benefit of large members and the detriment of everyone else. Too-big-to-fail banks, directors, officers, or employees being - too-big-to-manage, too-big-to-regulate, too-big-to-fail, too-big-to-prosecute, too-big-to-jail, too-big-to-change, and clearly too-big-to-behave --- downsize. Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by Wall Street mega banks during the financial crisis. The different/modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a one-size-fits-all approach. Disproportionate burden of banking laws and regulations on community banks. Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks. Unlevel playing field and a significant competitive disadvantage for community banks. Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies. Excessive, redundant and costly regulations. Regulatory accountability. Community banks dedicating resources to promoting economic growth. Steady increase in regulations over many decades. Regulatory threats to community banks and their communities. The Plan for Prosperity regarding: Basel III original intent. additional capital for small holding companies - modernize the Federal Reserves Policy Statement. Securities and Exchange Commission rules. reforming mortgage lending. accountability in bank exams by providing an appeals process. bank oversight and examinations - targeting risks. annual requirement for redundant privacy notices. consumer regulation - inclusive and accountable CFPB governance. arbitrary disparate impact fair lending causes of action. viability of mutual banks with new charter options. cost-benefit analysis to justify new rules. red tape in small business lending - burdensome data collection. community bank mortgage servicing. Treasury Assistant Secretary for Community Banks. subchapter S constraints. five-year loss carryback - support for lending during economic downturns. risk targeting in the Volcker Rule. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks. Credit Union Taxation and Expansion of Powers - Credit unions now indistinguishable from community banks, grown to control a significant share of the banking services market. Original business model now outdated. Credit unions strayed from founding purpose of serving individuals of modest means and with a common bond. Same financial services as community banks. Federal tax-exempt status, in exchange for serving their original mission is no longer justified. Credit unions paying their fair share of income taxes. Credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district . Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L). The exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks]. The Office of Management and Budget tax expenditure analysis - tax-exemption for credit unions result in loss of tax revenues of $9.46 billion over fiscal years 2014-2018. Credit union expansion of commercial lending powers - increasing the percentage of cap on member business lending (MBL). Loan growth at the expense of tax-paying community banks. Fundamental altering the exclusive member-focused character of credit unions - a condition for their original tax exemption. Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts. The same Call Report filing requirements for credit unions as those imposed on community banks. Tax subsidy and level the playing field between credit unions and tax-paying community banks. Farm Credit System - Expansionist agenda of the Farm Credit System (FCS). FCS almost the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status. Tax advantages - unfair competitive advantage. Follow narrow historic mission - abolish or be subject to taxation and oversight and regulation. Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives. Support and cooperation of Farm Credit Administration (FCA) - FCS straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities. FCS significant systemic and taxpayer bail-out risks. The FCS (only GSE) in active competition with community banks. Public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks). Funding and tax benefits impact on community banks. FCS not following its narrow historical mission. Follow narrow mission or abolish System. Abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity. FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight. Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks. Enhanced Cyber, Data and Payment Card Security - Establish a federal data security standard and notice requirement for all entities that store consumer data comparable to the Gramm-Leach-Bliley Act (GLBA) standards that apply to community banks. Shifting the liability for all costs associated with the data breach - including fraud losses and the cost of card reissuance - to the party that caused the breach. Consumer Financial Protection Bureau Mortgage Lending and Housing Finance Reform - Imprudent mortgage lending contribution to the mortgage meltdown and the financial crisis. Community banks common sense relationship lending and not participating in abusive and predatory lending practices. Community banks thriving on the strength of their reputations and incentive to make fair and reasonable loans. No need for prescriptive regulations to compel community banks to do the right thing for their customers. Curb imprudent lending practices. Not impacting responsible community bank loan products designed to meet the diverse needs of their customers, including borrowers with special needs and circumstances, first-time homebuyers, borrowers in rural and underserved areas, and low-to-moderate income borrowers. Regulators recognition of the difference between the non-traditional lending practiced by community banks and predatory lending practiced by others. Community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas should receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs). Special accommodations for small creditors, flexibility in serving the needs of customers and communities, particularly in rural areas, and the definition of underserved areas to include economically challenged areas. Reforms to the housing GSEs to include the existence of an impartial secondary market for residential mortgages, one that is financially strong and reliable, the need for some government tie to the secondary market to ensure the continued flow of credit and market liquidity during severe economic stress, no limit to full participation by community banks, and a return of private capital. Additional reforms to include community banks access to sell loans through an independent entity; no appropriation of community bank customer data for the purpose of cross selling financial services; maintain the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market; pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed; and no further consolidation of the housing finance system. Stop aggressively compelling community banks to repurchase transferred real estate mortgages for technical violations of underwriting agreements that had no bearing on the quality of the loan at the time of underwriting. Disparate Impact Fair Lending Causes of Action - Enforcement actions by the Department of Housing and Urban Development (HUD) and the Department of Justice (DOJ) - disparate impact. Additional obligation on community banks to consider such factors as race or national origin in credit decisions, which is specifically precluded by law - untenable situation Consumer Financial Protection Bureau Reform - Community banks regulatory relief to serve unique needs of their customers and not hinder new product development and innovation. Community bank flexibility to meet the unique needs of customers and community banks additional and unnecessary regulatory requirements to prevent their serving their communities. No a one-size-fits-all approach to CFPB regulations. Community banks not enduring any additional consumer regulatory burden on top of the existing regulatory burden. Single-Director governance of the CFPB versus a five-member commission. Prudential regulators participating with the CFPB in the rule-writing process. The Financial Stability Oversight Council (FSOC) power to veto CFPB rules. Broad definition of firms that grant credit being subject to the CFPB rules, and their robust supervision and examinations. Focus of any enhanced regulation of financial products on unregulated shadow financial companies. CFPBs efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products. CFPB holding mega banks and financial firms up to the existing standards for compliance with consumer laws, rules and regulations as required by community banks. Revised definitions in the Ability-to-Repay Qualified Mortgage rules of small creditor and rural areas, and expansion of the definition of underserved areas to include economically challenged areas. De Novo Community Bank Formation - Need for newly chartered (de novo) community banks. FDIC inhibiting de novo community bank formation. FDICs current position and a one-size-fits-all supervisory policy for de novos. Federal Home Loan Bank System - The Federal Home Loan Banks (FHLBs) partnership with community banks - short-term liquidity, long-term funding and other financial products and providing lendable funds for the local communities. Maintaining the regional structure, special functions and purposes of the FHLBs. The FHLB Systems health, stability and reliability for its members. FHFAs proposed (2014) revisions to FHLB membership eligibility requirements - impact on the FHLB System and its members including, but not limited to, regulatory burden, member balance sheet management, stability of the System, and continued reliability as a funding partner, future value of FHLB membership and the implications for membership decisions; and impact on housing and community development throughout the System. The proposed rule is also contrary to the will of Congress. FHLB System reliance as the sole aggregator or securitizer of residential mortgages for community banks, and the FHFAs imposition of an ongoing housing mission asset test on community financial institutions. Excessive Intervention in Monetary Policy - The sustained record-low zero interest rate policy (ZIRP) - disproportionate impact on community banks, senior citizens and discourages savings. Record-low interest rates for five years+ does not constitute temporary intervention but long-term and harmful manipulation. The limits to what Fed monetary policy can accomplish, especially given major offsetting negative effects. Legislation - H.R. 1309 - Systemic Risk Designation Act of 2105 (Amends Dodd-Frank Act and Consumer Protection Act regarding the designation of financial institutions as systemically important (SIFIs)) (all sections) (House) H.R. 1523 - Community Bank Access to Capital Act of 2015 (enhance community bank and thrift access to capital) (all sections) (House) H.R. 2205 and S. 961 - Data Security Act of 2015 (data breach and security, notifications, safeguards, GLBA compliance procedures) (all sections) (House and Senate, FDIC, OCC) H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate, FDIC, OCC) H.R. 3048 - Community Financial Institution Exemption Act (greater CFPB accountability in rulemaking to community financial institutions under $10 billion in assets) (all sections) (House) H.R. 1314 - Bipartisan Budget Act of 2015 (two year budget) (Title II - Agriculture, Section 201 - $3 billion crop insurance reduction) (House and Senate) H.R. 22 - DRIVE Act - highway and transportation funding (Amendment #86 Eliminate Privacy Notice Confusion Act, The Small Bank Exam Cycle Reform Act, The Holding Company Registration Threshold Equalization Act, and Amendment #34 Federal Reserve Bank stock dividend spending offset) (House) (House and Senate Conference Committee) S. 1484 - Financial Regulatory Improvement Act of 2015 (bank regulatory relief) (Title I - all sections) (House and Senate, FDIC, OCC) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate, FDIC, OCC) Comment Letters - Comment Letter - House, OMB, OCC, FDIC, Federal Reserve System, Proposed Agency Information Collection Activities (Call Report regulatory reform, Call Report regulatory burden and credit unions, Agency advocacy for community banks) (FFIEC 031 and FFIEC 041) Comment Letter - House, Senate, OCC, FDIC, Federal Reserve System (Combined impact of various regulations on community banks) Comment Letter - Federal Reserve System, FDIC, OCC (Regulator advocacy for community banks with National Credit Union Administration and Farm Credit Administration) Comment Letter - Federal Reserve System, FDIC, OCC (Remarks of Russell G. Golden, Chairman, Financial Accounting Standards Board regarding cause of the financial crisis and FASBs proposed Current Expected Credit Loss model (CECL)). Action Alerts - H.R. 1314 - Bipartisan Budget Act of 2015 - (two year budget) (Title II - Agriculture, Section 201 - $3 billion crop insurance reduction) (House) Miscellaneous - Regarding - Economic Growth and Recovery Paperwork Reduction Act (EGRPRA decennial regulatory review process) - specifically Prompt Corrective Action, Community Reinvestment Act, presentation of proposed rules, de novo bank formation, Call Reports, Small Bank Holding Company Policy Statement (as contained in CBAI Comment Letters - Docket ID FFIEC-2014-0001 and Docket ID FFIEC-2014-0001, Docket No. OP-1491) (House) Regarding - Senate Banking Committee hearing to consider Federal Reserve Board nominations (Senate) Regarding - Member Letter - reduction in Federal Reserve Bank stock dividend rate (House, FDIC, OCC) Regarding - reduction in Federal Reserve Bank stock dividend rate (House and Senate, FDIC, OCC) Regarding - Member Letter - Call Report regulatory relief (House) Regarding - Comments provided to banking regulators at the Chicago Federal Reserve Banks Economic Growth and Recovery Paperwork Reduction Act (EGRPRA decennial regulatory review process) outreach meeting - combined impact of regulations to address the same regulatory issues, and de novo bank formation Regarding - financial innovation (House) Regarding - Testimony before House Agricultural Committee hearing on the Farm Credit System (House)

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate, FDIC, OCC) Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by Wall Street mega banks during the financial crisis. The different/modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a one-size-fits-all approach. Disproportionate burden of banking laws and regulations on community banks. Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks. Unlevel playing field and a significant competitive disadvantage for community banks. Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies. Excessive, redundant and costly regulations. Regulatory accountability. Community banks dedicating resources to promoting economic growth. Steady increase in regulations over many decades. Regulatory threats to community banks and their communities. The Plan for Prosperity regarding: Basel III original intent. additional capital for small holding companies - modernize the Federal Reserves Policy Statement. Securities and Exchange Commission rules. reforming mortgage lending. accountability in bank exams by providing an appeals process. bank oversight and examinations - targeting risks. annual requirement for redundant privacy notices. consumer regulation - inclusive and accountable CFPB governance. arbitrary disparate impact fair lending causes of action. viability of mutual banks with new charter options. cost-benefit analysis to justify new rules. red tape in small business lending - burdensome data collection. community bank mortgage servicing. Treasury Assistant Secretary for Community Banks. subchapter S constraints. five-year loss carryback - support for lending during economic downturns. risk targeting in the Volcker Rule. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks. Consumer Financial Protection Bureau Mortgage Lending and Housing Finance Reform - Imprudent mortgage lending contribution to the mortgage meltdown and the financial crisis. Community banks common sense relationship lending and not participate in abusive and predatory lending practices. Community banks thriving on the strength of their reputations and incentive to make fair and reasonable loans. No need for prescriptive regulations to compel community banks to do the right thing for their customers. Curb imprudent lending practices. Not impacting responsible community bank loan products designed to meet the diverse needs of their customers, including borrowers with special needs and circumstances, first-time homebuyers, borrowers in rural and underserved areas, and low-to-moderate income borrowers. Regulators recognition of the difference between the non-traditional lending practiced by community banks and predatory lending practiced by others. Community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas should receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs). Special accommodations for small creditors, flexibility in serving the needs of customers and communities, particularly in rural areas, and the definition of underserved areas to include economically challenged areas. Reforms to the housing GSEs to include the existence of an impartial secondary market for residential mortgages, one that is financially strong and reliable, the need for some government tie to the secondary market to ensure the continued flow of credit and market liquidity during severe economic stress, no limit to full participation by community banks, and a return of private capital. Additional reforms to include community banks access to sell loans through an independent entity; no appropriation of community bank customer data for the purpose of cross selling financial services; maintain the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market; pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed; and no further consolidation of the housing finance system. Stop aggressively compelling community banks to repurchase transferred real estate mortgages for technical violations of underwriting agreements that had no bearing on the quality of the loan at the time of underwriting. Disparate Impact Fair Lending Causes of Action - Enforcement actions by the Department of Housing and Urban Development (HUD) and the Department of Justice (DOJ) - disparate impact. Additional obligation on community banks to consider such factors as race or national origin in credit decisions, which is specifically precluded by law - untenable situation. Consumer Financial Protection Bureau Reform - Community banks regulatory relief to serve unique needs of their customers and not hinder new product development and innovation. Community bank flexibility to meet the unique needs of customers and community banks additional and unnecessary regulatory requirements to prevent their serving their communities. No a one-size-fits-all approach to CFPB regulations. Community banks not enduring any additional consumer regulatory burden on top of the existing regulatory burden. Single-Director governance of the CFPB versus a five-member commission. Prudential regulators participating with the CFPB in the rule-writing process. The Financial Stability Oversight Council (FSOC) power to veto CFPB rules. Broad definition of firms that grant credit being subject to the CFPB rules, and their robust supervision and examinations. Focus of any enhanced regulation of financial products on unregulated shadow financial companies. CFPBs efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products. CFPB holding mega banks and financial firms up to the existing standards for compliance with consumer laws, rules and regulations as required by community banks. Federal Home Loan Bank System - The Federal Home Loan Banks (FHLBs) partnership with community banks - short-term liquidity, long-term funding and other financial products and providing lendable funds for the local communities. Maintaining the regional structure, special functions and purposes of the FHLBs. The FHLB Systems health, stability and reliability for its members. FHFAs proposed (2014) revisions to FHLB membership eligibility requirements - impact on the FHLB System and its members including, but not limited to, regulatory burden, member balance sheet management, stability of the System, and continued reliability as a funding partner, future value of FHLB membership and the implications for membership decisions; and impact on housing and community development throughout the System. The proposed rule is also contrary to the will of Congress. FHLB System reliance as the sole aggregator or securitizer of residential mortgages for community banks, and the FHFAs imposition of an ongoing housing mission asset test on community financial institutions. Excessive Intervention in Monetary Policy - The sustained record-low zero interest rate policy (ZIRP) - disproportionate impact on community banks, senior citizens and discourages savings. Record-low interest rates for five years+ does not constitute temporary intervention but long-term and harmful manipulation. The limits to what Fed monetary policy can accomplish, especially given major offsetting negative effects. Legislation - S. 1484 - Financial Regulatory Improvement Act of 2015 (bank regulatory relief) (Title I - all sections) (House and Senate, FDIC, OCC) H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate, FDIC, OCC) H.R. 2205 and S. 961 - Data Security Act of 2015 (data breach and security, notifications, safeguards, GLBA compliance procedures) (All sections) (House and Senate, FDIC, OCC) H.R. 3048 - Community Financial Institution Exemption Act (greater CFPB accountability in rulemaking to community financial institutions under $10 billion in assets) (all sections) (House) H.R. 22 - DRIVE Act - highway and transportation funding (Amendment #86 Eliminate Privacy Notice Confusion Act, The Small Bank Exam Cycle Reform Act, The Holding Company Registration Threshold Equalization Act, and Amendment #34 Federal Reserve Bank stock dividend spending offset) (House) (House and Senate Conference Committee) Miscellaneous - Regarding Economic Growth and Recovery Paperwork Reduction Act (EGRPRA decennial regulatory review process) - specifically Prompt Corrective Action, Community Reinvestment Act, presentation of proposed rules, de novo bank formation, Call Reports, Small Bank Holding Company Policy Statement (as contained in CBAI Comment Letters - Docket ID FFIEC-2014-0001 and Docket ID FFIEC-2014-0001, Docket No. OP-1491) (House)

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate, FDIC, OCC) Credit Union Taxation and Expansion of Powers - Credit unions now indistinguishable from community banks, grown to control a significant share of the banking services market. Original business model now outdated. Credit unions strayed from founding purpose of serving individuals of modest means and with a common bond. Same financial services as community banks. Federal tax-exempt status, in exchange for serving their original mission is no longer justified. Credit unions paying their fair share of income taxes. Credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district. Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L). The exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks]. The Office of Management and Budget tax expenditure analysis - tax-exemption for credit unions result in loss of tax revenues of $9.46 billion over fiscal years 2014-2018. Credit union expansion of commercial lending powers - increasing the percentage of assets cap on member business lending (MBL). Loan growth at the expense of tax-paying community banks. Fundamental altering the exclusive member-focused character of credit unions - a condition for their original tax exemption. Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts. The same Call Report filing requirements for credit unions as those imposed on community banks. Tax subsidy and level the playing field between credit unions and tax-paying community banks. Farm Credit System - Expansionist agenda of the Farm Credit System (FCS). FCS almost the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status. Tax advantages - unfair competitive advantage. Follow narrow historic mission - abolish or be subject to taxation and oversight and regulation. Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives. Support and cooperation of Farm Credit Administration (FCA) - FCS straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities. FCS significant systemic and taxpayer bail-out risks. The FCS (only GSE) in active competition with community banks. Public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks). Funding and tax benefits impact on community banks. FCS not following its narrow historical mission. Follow narrow mission or abolish System. Abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity. FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight. Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks. Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by Wall Street mega banks during the financial crisis. The different/modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a one-size-fits-all approach. Disproportionate burden of banking laws and regulations on community banks. Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks. Unlevel playing field and a significant competitive disadvantage for community banks. Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies. Excessive, redundant and costly regulations. Regulatory accountability. Community banks dedicating resources to promoting economic growth. Steady increase in regulations over many decades. Regulatory threats to community banks and their communities. The Plan for Prosperity regarding: Basel III original intent. additional capital for small holding companies - modernize the Federal Reserves Policy Statement. Securities and Exchange Commission rules. reforming mortgage lending. accountability in bank exams by providing an appeals process. bank oversight and examinations - targeting risks. annual requirement for redundant privacy notices. consumer regulation - inclusive and accountable CFPB governance. arbitrary disparate impact fair lending causes of action. viability of mutual banks with new charter options. cost-benefit analysis to justify new rules. red tape in small business lending - burdensome data collection. community bank mortgage servicing. Treasury Assistant Secretary for Community Banks. subchapter S constraints. five-year loss carryback - support for lending during economic downturns. risk targeting in the Volcker Rule. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks. Legislation - S. 1484 - Financial Regulatory Improvement Act of 2015 (bank regulatory relief) (Title I - all sections) (House and Senate, FDIC, OCC) H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate, FDIC, OCC) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate, FDIC, OCC) Comment Letters - Comment Letter - House, OMB, OCC, FDIC, Federal Reserve System, Proposed Agency Information Collection Activities (Call Report regulatory reform, Call Report regulatory burden and credit unions, Agency advocacy for community banks) (FFIEC 031 and FFIEC 041) Comment Letter - Federal Reserve System, FDIC, OCC (Regulator advocacy for community banks with National Credit Union Administration and Farm Credit Administration)

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate, FDIC, OCC) Too-to-Fail - Reform the financial system. The severity of a future financial crisis. The perception and reality of too-big-to-fail. Taxpayer bailouts of mega banks and financial firms. Mega bank size, complexity and interconnectedness, and candidacy for future bailouts. The number of community banks falling by more than half (currently 6,200 institutions) and now represent less than one-fifth of banking professions assets. Causes of the mortgage meltdown and financial crisis. Protection of the nation and the banking profession from a repeat of massive financial destruction. Taxpayer-funded bailouts of too-big-to-fail banks and financial firms and their numerous violations of the law, often criminal violations. Effective management, supervision, discipline, or resolution of too-big-to-fail banks and financial firms. Mega bank multi-trillion dollars financial assistance versus community banks assistance and more than 500 failed community banks. Downsizing too-big-to-fail banks and financial firms. The fundamental American constitutional right of equal justice under the law applicability when it comes to the mega banks. The U.S. two-tiered system of justice - too-big-to-fail banks and financial firms and everyone else. The Department of Justice (DOJ) - laggard in prosecuting crimes stemming from the financial crisis. Banking regulators and the DOJ aggressively pursuing actions against community banks, their directors, and officers with board resolutions, MOUs, C&Ds, consent orders, monetary penalties, barring individuals from banking, criminal prosecution, and other actions. No mandatory Prompt Corrective Action (PCA) capital enforcement orders against any bank larger than $30 billion in assets, yet 1,400 PCAs against community banks. Evidence of a clear double standard. Opponents of downsizing the mega banks (include their paid association cheerleaders) consistently blocking meaningful reforms and obfuscating the issue of too-big-to-fail for the benefit of large members and the detriment of everyone else. Too-big-to-fail banks, directors, officers, or employees being - too-big-to-manage, too-big-to-regulate, too-big-to-fail, too-big-to-prosecute, too-big-to-jail, too-big-to-change, and clearly too-big-to-behave --- downsize. Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by Wall Street mega banks during the financial crisis. The different/modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a one-size-fits-all approach. Disproportionate burden of banking laws and regulations on community banks. Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks. Unlevel playing field and a significant competitive disadvantage for community banks. Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies. Excessive, redundant and costly regulations. Regulatory accountability. Community banks dedicating resources to promoting economic growth. Steady increase in regulations over many decades. Regulatory threats to community banks and their communities. The Plan for Prosperity regarding: Basel III original intent. additional capital for small holding companies - modernize the Federal Reserves Policy Statement. Securities and Exchange Commission rules. reforming mortgage lending. accountability in bank exams by providing an appeals process. bank oversight and examinations - targeting risks. annual requirement for redundant privacy notices. consumer regulation - inclusive and accountable CFPB governance. arbitrary disparate impact fair lending causes of action. viability of mutual banks with new charter options. cost-benefit analysis to justify new rules. red tape in small business lending - burdensome data collection. community bank mortgage servicing. Treasury Assistant Secretary for Community Banks. subchapter S constraints. five-year loss carryback - support for lending during economic downturns. risk targeting in the Volcker Rule. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks. Credit Union Taxation and Expansion of Powers - Credit unions now indistinguishable from community banks, grown to control a significant share of the banking services market. Original business model now outdated. Credit unions strayed from founding purpose of serving individuals of modest means and with a common bond. Same financial services as community banks. Federal tax-exempt status, in exchange for serving their original mission is no longer justified. Credit unions paying their fair share of income taxes. Credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district . Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L). The exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks]. The Office of Management and Budget tax expenditure analysis - tax-exemption for credit unions result in loss of tax revenues of $9.46 billion over fiscal years 2014-2018. Credit union expansion of commercial lending powers - increasing the percentage of cap on member business lending (MBL). Loan growth at the expense of tax-paying community banks. Fundamental altering the exclusive member-focused character of credit unions - a condition for their original tax exemption. Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts. The same Call Report filing requirements for credit unions as those imposed on community banks. Tax subsidy and level the playing field between credit unions and tax-paying community banks. Farm Credit System - Expansionist agenda of the Farm Credit System (FCS). FCS almost the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status. Tax advantages - unfair competitive advantage. Follow narrow historic mission - abolish or be subject to taxation and oversight and regulation. Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives. Support and cooperation of Farm Credit Administration (FCA) - FCS straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities. FCS significant systemic and taxpayer bail-out risks. The FCS (only GSE) in active competition with community banks. Public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks). Funding and tax benefits impact on community banks. FCS not following its narrow historical mission. Follow narrow mission or abolish System. Abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity. FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight. Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks. Enhanced Cyber, Data and Payment Card Security - Establish a federal data security standard and notice requirement for all entities that store consumer data comparable to the Gramm-Leach-Bliley Act (GLBA) standards that apply to community banks. Shifting the liability for all costs associated with the data breach - including fraud losses and the cost of card reissuance - to the party that caused the breach. Consumer Financial Protection Bureau Mortgage Lending and Housing Finance Reform - Imprudent mortgage lending contribution to the mortgage meltdown and the financial crisis. Community banks common sense relationship lending and not participating in abusive and predatory lending practices. Community banks thriving on the strength of their reputations and incentive to make fair and reasonable loans. No need for prescriptive regulations to compel community banks to do the right thing for their customers. Curb imprudent lending practices. Not impacting responsible community bank loan products designed to meet the diverse needs of their customers, including borrowers with special needs and circumstances, first-time homebuyers, borrowers in rural and underserved areas, and low-to-moderate income borrowers. Regulators recognition of the difference between the non-traditional lending practiced by community banks and predatory lending practiced by others. Community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas should receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs). Special accommodations for small creditors, flexibility in serving the needs of customers and communities, particularly in rural areas, and the definition of underserved areas to include economically challenged areas. Reforms to the housing GSEs to include the existence of an impartial secondary market for residential mortgages, one that is financially strong and reliable, the need for some government tie to the secondary market to ensure the continued flow of credit and market liquidity during severe economic stress, no limit to full participation by community banks, and a return of private capital. Additional reforms to include community banks access to sell loans through an independent entity; no appropriation of community bank customer data for the purpose of cross selling financial services; maintain the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market; pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed; and no further consolidation of the housing finance system. Stop aggressively compelling community banks to repurchase transferred real estate mortgages for technical violations of underwriting agreements that had no bearing on the quality of the loan at the time of underwriting. Disparate Impact Fair Lending Causes of Action - Enforcement actions by the Department of Housing and Urban Development (HUD) and the Department of Justice (DOJ) - disparate impact. Additional obligation on community banks to consider such factors as race or national origin in credit decisions, which is specifically precluded by law - untenable situation Consumer Financial Protection Bureau Reform - Community banks regulatory relief to serve unique needs of their customers and not hinder new product development and innovation. Community bank flexibility to meet the unique needs of customers and community banks additional and unnecessary regulatory requirements to prevent their serving their communities. No a one-size-fits-all approach to CFPB regulations. Community banks not enduring any additional consumer regulatory burden on top of the existing regulatory burden. Single-Director governance of the CFPB versus a five-member commission. Prudential regulators participating with the CFPB in the rule-writing process. The Financial Stability Oversight Council (FSOC) power to veto CFPB rules. Broad definition of firms that grant credit being subject to the CFPB rules, and their robust supervision and examinations. Focus of any enhanced regulation of financial products on unregulated shadow financial companies. CFPBs efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products. CFPB holding mega banks and financial firms up to the existing standards for compliance with consumer laws, rules and regulations as required by community banks. Revised definitions in the Ability-to-Repay Qualified Mortgage rules of small creditor and rural areas, and expansion of the definition of underserved areas to include economically challenged areas. De Novo Community Bank Formation - Need for newly chartered (de novo) community banks. FDIC inhibiting de novo community bank formation. FDICs current position and a one-size-fits-all supervisory policy for de novos. Federal Home Loan Bank System - The Federal Home Loan Banks (FHLBs) partnership with community banks - short-term liquidity, long-term funding and other financial products and providing lendable funds for the local communities. Maintaining the regional structure, special functions and purposes of the FHLBs. The FHLB Systems health, stability and reliability for its members. FHFAs proposed (2014) revisions to FHLB membership eligibility requirements - impact on the FHLB System and its members including, but not limited to, regulatory burden, member balance sheet management, stability of the System, and continued reliability as a funding partner, future value of FHLB membership and the implications for membership decisions; and impact on housing and community development throughout the System. The proposed rule is also contrary to the will of Congress. FHLB System reliance as the sole aggregator or securitizer of residential mortgages for community banks, and the FHFAs imposition of an ongoing housing mission asset test on community financial institutions. Excessive Intervention in Monetary Policy - The sustained record-low zero interest rate policy (ZIRP) - disproportionate impact on community banks, senior citizens and discourages savings. Record-low interest rates for five years+ does not constitute temporary intervention but long-term and harmful manipulation. The limits to what Fed monetary policy can accomplish, especially given major offsetting negative effects. Legislation - H.R. 1309 - Systemic Risk Designation Act of 2105 (Amends Dodd-Frank Act and Consumer Protection Act regarding the designation of financial institutions as systemically important (SIFIs)) (all sections) (House) H.R. 1523 - Community Bank Access to Capital Act of 2015 (enhance community bank and thrift access to capital) (all sections) (House) H.R. 2205 and S. 961 - Data Security Act of 2015 (data breach and security, notifications, safeguards, GLBA compliance procedures) (all sections) (House and Senate, FDIC, OCC) H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate, FDIC, OCC) H.R. 3048 - Community Financial Institution Exemption Act (greater CFPB accountability in rulemaking to community financial institutions under $10 billion in assets) (all sections) (House) H.R. 1314 - Bipartisan Budget Act of 2015 (two year budget) (Title II - Agriculture, Section 201 - $3 billion crop insurance reduction) (House and Senate) H.R. 22 - DRIVE Act - highway and transportation funding (Amendment #86 Eliminate Privacy Notice Confusion Act, The Small Bank Exam Cycle Reform Act, The Holding Company Registration Threshold Equalization Act, and Amendment #34 Federal Reserve Bank stock dividend spending offset) (House) (House and Senate Conference Committee) S. 1484 - Financial Regulatory Improvement Act of 2015 (bank regulatory relief) (Title I - all sections) (House and Senate, FDIC, OCC) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate, FDIC, OCC) Comment Letters - Comment Letter - House, OMB, OCC, FDIC, Federal Reserve System, Proposed Agency Information Collection Activities (Call Report regulatory reform, Call Report regulatory burden and credit unions, Agency advocacy for community banks) (FFIEC 031 and FFIEC 041) Comment Letter - House, Senate, OCC, FDIC, Federal Reserve System (Combined impact of various regulations on community banks) Comment Letter - Federal Reserve System, FDIC, OCC (Regulator advocacy for community banks with National Credit Union Administration and Farm Credit Administration) Comment Letter - Federal Reserve System, FDIC, OCC (Remarks of Russell G. Golden, Chairman, Financial Accounting Standards Board regarding cause of the financial crisis and FASBs proposed Current Expected Credit Loss model (CECL)). Action Alerts - H.R. 1314 - Bipartisan Budget Act of 2015 - (two year budget) (Title II - Agriculture, Section 201 - $3 billion crop insurance reduction) (House) Miscellaneous - Regarding - Economic Growth and Recovery Paperwork Reduction Act (EGRPRA decennial regulatory review process) - specifically Prompt Corrective Action, Community Reinvestment Act, presentation of proposed rules, de novo bank formation, Call Reports, Small Bank Holding Company Policy Statement (as contained in CBAI Comment Letters - Docket ID FFIEC-2014-0001 and Docket ID FFIEC-2014-0001, Docket No. OP-1491) (House) Regarding - Senate Banking Committee hearing to consider Federal Reserve Board nominations (Senate) Regarding - Member Letter - reduction in Federal Reserve Bank stock dividend rate (House, FDIC, OCC) Regarding - reduction in Federal Reserve Bank stock dividend rate (House and Senate, FDIC, OCC) Regarding - Member Letter - Call Report regulatory relief (House) Regarding - Comments provided to banking regulators at the Chicago Federal Reserve Banks Economic Growth and Recovery Paperwork Reduction Act (EGRPRA decennial regulatory review process) outreach meeting - combined impact of regulations to address the same regulatory issues, and de novo bank formation Regarding - financial innovation (House) Regarding - Testimony before House Agricultural Committee hearing on the Farm Credit System (House)

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate) Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by Wall Street mega banks during the financial crisis. The different/modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a one-size-fits-all approach. Disproportionate burden of banking laws and regulations on community banks. Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks. Unlevel playing field and a significant competitive disadvantage for community banks. Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies. Excessive, redundant and costly regulations. Regulatory accountability. Community banks dedicating resources to promoting economic growth. Steady increase in regulations over many decades. Regulatory threats to community banks and their communities. The Plan for Prosperity regarding: Basel III original intent. additional capital for small holding companies - modernize the Federal Reserves Policy Statement. Securities and Exchange Commission rules. reforming mortgage lending. accountability in bank exams by providing an appeals process. bank oversight and examinations - targeting risks. annual requirement for redundant privacy notices. consumer regulation - inclusive and accountable CFPB governance. arbitrary disparate impact fair lending causes of action. viability of mutual banks with new charter options. cost-benefit analysis to justify new rules. red tape in small business lending - burdensome data collection. community bank mortgage servicing. Treasury Assistant Secretary for Community Banks. subchapter S constraints. five-year loss carryback - support for lending during economic downturns. risk targeting in the Volcker Rule. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks. Legislation - H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate) H.R. 2205 and S. 961 - Data Security Act of 2015 (data breach and security, notifications, safeguards, GLBA compliance procedures) (All sections) (House and Senate) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate) Comment Letters - Comment Letter - National Credit Union Administration regarding proposed rulemaking for Part 723 (RIN 3133-AE37) to rewrite rules governing credit union member business lending (House and Senate) Action Alerts - National Credit Union Administration regarding proposed rulemaking to rewrite rules governing credit union member business lending

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate) Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by Wall Street mega banks during the financial crisis. The different/modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a one-size-fits-all approach. Disproportionate burden of banking laws and regulations on community banks. Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks. Unlevel playing field and a significant competitive disadvantage for community banks. Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies. Excessive, redundant and costly regulations. Regulatory accountability. Community banks dedicating resources to promoting economic growth. Steady increase in regulations over many decades. Regulatory threats to community banks and their communities. The Plan for Prosperity regarding: Basel III original intent. additional capital for small holding companies - modernize the Federal Reserves Policy Statement. Securities and Exchange Commission rules. reforming mortgage lending. accountability in bank exams by providing an appeals process. bank oversight and examinations - targeting risks. annual requirement for redundant privacy notices. consumer regulation - inclusive and accountable CFPB governance. arbitrary disparate impact fair lending causes of action. viability of mutual banks with new charter options. cost-benefit analysis to justify new rules. red tape in small business lending - burdensome data collection. community bank mortgage servicing. Treasury Assistant Secretary for Community Banks. subchapter S constraints. five-year loss carryback - support for lending during economic downturns. risk targeting in the Volcker Rule. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks. Consumer Financial Protection Bureau Mortgage Lending and Housing Finance Reform - Imprudent mortgage lending contribution to the mortgage meltdown and the financial crisis. Community banks common sense relationship lending and not participate in abusive and predatory lending practices. Community banks thriving on the strength of their reputations and incentive to make fair and reasonable loans. No need for prescriptive regulations to compel community banks to do the right thing for their customers. Curb imprudent lending practices. Not impacting responsible community bank loan products designed to meet the diverse needs of their customers, including borrowers with special needs and circumstances, first-time homebuyers, borrowers in rural and underserved areas, and low-to-moderate income borrowers. Regulators recognition of the difference between the non-traditional lending practiced by community banks and predatory lending practiced by others. Community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas should receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs). Special accommodations for small creditors, flexibility in serving the needs of customers and communities, particularly in rural areas, and the definition of underserved areas to include economically challenged areas. Reforms to the housing GSEs to include the existence of an impartial secondary market for residential mortgages, one that is financially strong and reliable, the need for some government tie to the secondary market to ensure the continued flow of credit and market liquidity during severe economic stress, no limit to full participation by community banks, and a return of private capital. Additional reforms to include community banks access to sell loans through an independent entity; no appropriation of community bank customer data for the purpose of cross selling financial services; maintain the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market; pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed; and no further consolidation of the housing finance system. Stop aggressively compelling community banks to repurchase transferred real estate mortgages for technical violations of underwriting agreements that had no bearing on the quality of the loan at the time of underwriting. Disparate Impact Fair Lending Causes of Action - Enforcement actions by the Department of Housing and Urban Development (HUD) and the Department of Justice (DOJ) - disparate impact. Additional obligation on community banks to consider such factors as race or national origin in credit decisions, which is specifically precluded by law - untenable situation. Consumer Financial Protection Bureau Reform - Community banks regulatory relief to serve unique needs of their customers and not hinder new product development and innovation. Community bank flexibility to meet the unique needs of customers and community banks additional and unnecessary regulatory requirements to prevent their serving their communities. No a one-size-fits-all approach to CFPB regulations. Community banks not enduring any additional consumer regulatory burden on top of the existing regulatory burden. Single-Director governance of the CFPB versus a five-member commission. Prudential regulators participating with the CFPB in the rule-writing process. The Financial Stability Oversight Council (FSOC) power to veto CFPB rules. Broad definition of firms that grant credit being subject to the CFPB rules, and their robust supervision and examinations. Focus of any enhanced regulation of financial products on unregulated shadow financial companies. CFPBs efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products. CFPB holding mega banks and financial firms up to the existing standards for compliance with consumer laws, rules and regulations as required by community banks. Federal Home Loan Bank System - The Federal Home Loan Banks (FHLBs) partnership with community banks - short-term liquidity, long-term funding and other financial products and providing lendable funds for the local communities. Maintaining the regional structure, special functions and purposes of the FHLBs. The FHLB Systems health, stability and reliability for its members. FHFAs proposed (2014) revisions to FHLB membership eligibility requirements - impact on the FHLB System and its members including, but not limited to, regulatory burden, member balance sheet management, stability of the System, and continued reliability as a funding partner, future value of FHLB membership and the implications for membership decisions; and impact on housing and community development throughout the System. The proposed rule is also contrary to the will of Congress. FHLB System reliance as the sole aggregator or securitizer of residential mortgages for community banks, and the FHFAs imposition of an ongoing housing mission asset test on community financial institutions. Excessive Intervention in Monetary Policy - The sustained record-low zero interest rate policy (ZIRP) - disproportionate impact on community banks, senior citizens and discourages savings. Record-low interest rates for five years+ does not constitute temporary intervention but long-term and harmful manipulation. The limits to what Fed monetary policy can accomplish, especially given major offsetting negative effects. Legislation - H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate) H.R. 2205 and S. 961 - Data Security Act of 2015 (data breach and security, notifications, safeguards, GLBA compliance procedures) (All sections) (House and Senate) Comment Letters - Comment Letter - CFPB, grace period for enforcement and liability in the implementation, and delay in the implementation of the TRID Action Alerts - H.R. 1233 and S. 812 - Community Lending Enhancement and Regulatory (CLEAR) Relief Act of 2015 (community bank regulatory relief) (all sections) (House and Senate), and H.R. 1523 and S. 1816 - Community Bank Access to Capital (enhance community bank and thrift access to capital) (all sections) (House and Senate) Miscellaneous - Regarding CFPB, delay in implementation of TRID and period of restrained enforcement and liability, the definition of rural and underserved areas in the QM, regulatory burden on community banks, declining number of community banks and community bank consolidation (House)

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate) Farm Credit System - Expansionist agenda of the Farm Credit System (FCS). FCS almost the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status. Tax advantages - unfair competitive advantage. Follow narrow historic mission - abolish or be subject to taxation and oversight and regulation. Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives. Support and cooperation of Farm Credit Administration (FCA) - FCS straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities. FCS significant systemic and taxpayer bail-out risks. The FCS (only GSE) in active competition with community banks. Public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks). Funding and tax benefits impact on community banks. FCS not following its narrow historical mission. Follow narrow mission or abolish System. Abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity. FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight. Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks. Miscellaneous - Regarding CFPB, delay in implementation of TRID and period of restrained enforcement and liability, the definition of rural and underserved areas in the QM, regulatory burden on community banks, declining number of community banks and community bank consolidation (House)

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate) Too-to-Fail - Reform the financial system. The severity of a future financial crisis. The perception and reality of too-big-to-fail. Taxpayer bailouts of mega banks and financial firms. Mega bank size, complexity and interconnectedness, and candidacy for future bailouts. The number of community banks falling by more than half (currently 6,200 institutions) and now represent less than one-fifth of banking professions assets. Causes of the mortgage meltdown and financial crisis. Protection of the nation and the banking profession from a repeat of massive financial destruction. Taxpayer-funded bailouts of too-big-to-fail banks and financial firms and their numerous violations of the law, often criminal violations. Effectively management, supervision, discipline, or resolution of too-big-to-fail banks and financial firms. Mega bank multi-trillion dollars financial assistance. Community banks assistance and more than 500 failed community banks. Downsizing too-big-to-fail banks and financial firms. The fundamental American constitutional right of equal justice under the law applicability when it comes to the mega banks. The U.S. two-tiered system of justice - too-big-to-fail banks and financial firms and everyone else. The Department of Justice (DOJ) - laggard in prosecuting crimes stemming from the financial crisis. Banking regulators and the DOJ aggressively pursuing actions against community banks, their directors, and officers with board resolutions, MOUs, C&Ds, consent orders, monetary penalties, barring individuals from banking, criminal prosecution, and other actions. No mandatory Prompt Corrective Action (PCA) capital enforcement orders against any bank larger than $30 billion in assets, yet 1,400 PCAs against community banks. Evidence of a clear double standard. Opponents of downsizing the mega banks (include their paid association cheerleaders) consistently blocking meaningful reforms and obfuscating the issue of too-big-to-fail for the benefit of large members and the detriment of everyone else. Too-big-to-fail banks, directors, officers, or employees being - too-big-to-manage, too-big-to-regulate, too-big-to-fail, too-big-to-prosecute, too-big-to-jail, too-big-to-change, and clearly too-big-to-behave --- downsize. Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by Wall Street mega banks during the financial crisis. The different/modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a one-size-fits-all approach. Disproportionate burden of banking laws and regulations on community banks. Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks. Unlevel playing field and a significant competitive disadvantage for community banks. Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies. Excessive, redundant and costly regulations. Regulatory accountability. Community banks dedicating resources to promoting economic growth. Steady increase in regulations over many decades. Regulatory threats to community banks and their communities. The Plan for Prosperity regarding: Basel III original intent. additional capital for small holding companies - modernize the Federal Reserves Policy Statement. Securities and Exchange Commission rules. reforming mortgage lending. accountability in bank exams by providing an appeals process. bank oversight and examinations - targeting risks. annual requirement for redundant privacy notices. consumer regulation - inclusive and accountable CFPB governance. arbitrary disparate impact fair lending causes of action. viability of mutual banks with new charter options. cost-benefit analysis to justify new rules. red tape in small business lending - burdensome data collection. community bank mortgage servicing. Treasury Assistant Secretary for Community Banks. subchapter S constraints. five-year loss carryback - support for lending during economic downturns. risk targeting in the Volcker Rule. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks. Credit Union Taxation and Expansion of Powers - Credit unions now indistinguishable from community banks, grown to control a significant share of the banking services market. Original business model now outdated. Credit unions strayed from founding purpose of serving individuals of modest means and with a common bond. Same financial services as community banks. Federal tax-exempt status, in exchange for serving their original mission is no longer justified. Credit unions paying their fair share of income taxes Credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L). The exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks]. The Office of Management and Budget tax expenditure analysis - tax-exemption for credit unions result in loss of tax revenues of $9.46 billion over fiscal years 2014-2018. Credit union expansion of commercial lending powers - increasing the percentage of cap on member business lending (MBL). Loan growth at the expense of tax-paying community banks. Fundamental altering the exclusive member-focused character of credit unions - a condition for their original tax exemption. Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts. The same Call Report filing requirements for credit unions as those imposed on community banks. Tax subsidy and level the playing field between credit unions and tax-paying community banks. Farm Credit System - Expansionist agenda of the Farm Credit System (FCS). FCS almost the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status. Tax advantages - unfair competitive advantage. Follow narrow historic mission - abolish or be subject to taxation and oversight and regulation. Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives. Support and cooperation of Farm Credit Administration (FCA) - FCS straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities. FCS significant systemic and taxpayer bail-out risks. The FCS (only GSE) in active competition with community banks. Public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks). Funding and tax benefits impact on community banks. FCS not following its narrow historical mission. Follow narrow mission or abolish System. Abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity. FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight. Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks. Enhanced Cyber, Data and Payment Card Security - Establish a federal data security standard and notice requirement for all entities that store consumer data comparable to the Gramm-Leach-Bliley Act (GLBA) standards that apply to community banks. Shifting the liability for all costs associated with the data breach - including fraud losses and the cost of card reissuance - to the party that caused the breach. Consumer Financial Protection Bureau Mortgage Lending and Housing Finance Reform - Imprudent mortgage lending contribution to the mortgage meltdown and the financial crisis. Community banks common sense relationship lending and not participating in abusive and predatory lending practices. Community banks thriving on the strength of their reputations and incentive to make fair and reasonable loans. No need for prescriptive regulations to compel community banks to do the right thing for their customers. Curb imprudent lending practices. Not impacting responsible community bank loan products designed to meet the diverse needs of their customers, including borrowers with special needs and circumstances, first-time homebuyers, borrowers in rural and underserved areas, and low-to-moderate income borrowers. Regulators recognition of the difference between the non-traditional lending practiced by community banks and predatory lending practiced by others. Community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas should receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs). Special accommodations for small creditors, flexibility in serving the needs of customers and communities, particularly in rural areas, and the definition of underserved areas to include economically challenged areas. Reforms to the housing GSEs to include the existence of an impartial secondary market for residential mortgages, one that is financially strong and reliable, the need for some government tie to the secondary market to ensure the continued flow of credit and market liquidity during severe economic stress, no limit to full participation by community banks, and a return of private capital. Additional reforms to include community banks access to sell loans through an independent entity; no appropriation of community bank customer data for the purpose of cross selling financial services; maintain the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market; pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed; and no further consolidation of the housing finance system. Stop aggressively compelling community banks to repurchase transferred real estate mortgages for technical violations of underwriting agreements that had no bearing on the quality of the loan at the time of underwriting. Disparate Impact Fair Lending Causes of Action - Enforcement actions by the Department of Housing and Urban Development (HUD) and the Department of Justice (DOJ) - disparate impact. Additional obligation on community banks to consider such factors as race or national origin in credit decisions, which is specifically precluded by law - untenable situation Consumer Financial Protection Bureau Reform - Community banks regulatory relief to serve unique needs of their customers and not hinder new product development and innovation. Community bank flexibility to meet the unique needs of customers and community banks additional and unnecessary regulatory requirements to prevent their serving their communities. No a one-size-fits-all approach to CFPB regulations. Community banks not enduring any additional consumer regulatory burden on top of the existing regulatory burden. Single-Director governance of the CFPB versus a five-member commission. Prudential regulators participating with the CFPB in the rule-writing process. The Financial Stability Oversight Council (FSOC) power to veto CFPB rules. Broad definition of firms that grant credit being subject to the CFPB rules, and their robust supervision and examinations. Focus of any enhanced regulation of financial products on unregulated shadow financial companies. CFPBs efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products. CFPB holding mega banks and financial firms up to the existing standards for compliance with consumer laws, rules and regulations as required by community banks. Revised definitions in the Ability-to-Repay Qualified Mortgage rules of small creditor and rural areas, and expansion of the definition of underserved areas to include economically challenged areas. De Novo Community Bank Formation - Need for newly chartered (de novo) community banks. FDIC inhibiting de novo community bank formation. FDICs current position and a one-size-fits-all supervisory policy for de novos. Federal Home Loan Bank System - The Federal Home Loan Banks (FHLBs) partnership with community banks - short-term liquidity, long-term funding and other financial products and providing lendable funds for the local communities. Maintaining the regional structure, special functions and purposes of the FHLBs. The FHLB Systems health, stability and reliability for its members. FHFAs proposed (2014) revisions to FHLB membership eligibility requirements - impact on the FHLB System and its members including, but not limited to, regulatory burden, member balance sheet management, stability of the System, and continued reliability as a funding partner, future value of FHLB membership and the implications for membership decisions; and impact on housing and community development throughout the System. The proposed rule is also contrary to the will of Congress. FHLB System reliance as the sole aggregator or securitizer of residential mortgages for community banks, and the FHFAs imposition of an ongoing housing mission asset test on community financial institutions. Excessive Intervention in Monetary Policy - The sustained record-low zero interest rate policy (ZIRP) - disproportionate impact on community banks, senior citizens and discourages savings. Record-low interest rates for five years+ does not constitute temporary intervention but long-term and harmful manipulation. The limits to what Fed monetary policy can accomplish, especially given major offsetting negative effects. Legislation - H.R. 1523 - Community Bank Access to Capital Act of 2015 (enhance community bank and thrift access to capital) (all sections) (House and Senate) H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate) H.R. 2205 and S. 961 - Data Security Act of 2015 (data breach and security, notifications, safeguards, GLBA compliance procedures) (All sections) (House and Senate) H.R. 1188 - The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate) Highway Trust Fund Reauthorization - (Senate versions proposed reduction of dividends paid on Federal Reserve Bank stock as pay-for) (Senate) H.R. 1941 - Financial Institutions Examination Fairness and Reform Act (regulatory examinations standards and FFIEC Ombudsman) (all sections) (House) S. 1440 and H.R. 1422 - Credit Union Residential Loan Parity Act (exclude loans to non-primary residence 1-4 family dwellings from member business lending cap) (all sections) (Senate) State of Illinois legislation - (sharing of IDFPR state bank examination reports with the Federal Home Loan Bank of Chicago) Comment Letters - Comment Letter - CFPB, grace period for enforcement and liability in the implementation, and delay in the implementation of the TRID Comment Letter - Department of Labor, proposed increase in the salary threshold for employees who are exempt from overtime mandates of the Fair Labor Standards Act Comment Letter - National Credit Union Administration, comments on proposed rulemaking for Part 723 (RIN 3133-AE37) to rewrite rules governing credit union member business lending (House and Senate) Comment Letter - FDIC, Notice of Proposed Rulemaking and request for Comments RIN 3064-AE37 to refine the deposit insurance assessment system for small depository institutions Action Alerts - H.R. 1233 and S. 812 - Community Lending Enhancement and Regulatory (CLEAR) Relief Act of 2015 (community bank regulatory relief) (all sections) (House and Senate), and H.R. 1523 and S. 1816 - Community Bank Access to Capital (enhance community bank and thrift access to capital) (all sections) (House and Senate) Highway Trust Fund Reauthorization - (Senate versions proposed reduction of dividends paid on Federal Reserve Bank stock as pay-for) (Senate) National Credit Union Administration regarding proposed rulemaking to rewrite rules governing credit union member business lending Miscellaneous - Regarding CFPB, delay in implementation of TRID and period of restrained enforcement and liability, the definition of rural and underserved areas in the QM, regulatory burden on community banks, declining number of community banks and community bank consolidation (House) Current community bank regulatory examination environment (Senate)

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate) Too-to-Fail - Reform the financial system. The severity of a future financial crisis. The perception and reality of too-big-to-fail. Taxpayer bailouts of mega banks and financial firms. Mega bank size, complexity and interconnectedness, and candidacy for future bailouts. The number of community banks falling by more than half (currently 6,200 institutions) and now represent less than one-fifth of banking professions assets. Causes of the mortgage meltdown and financial crisis. Protection of the nation and the banking profession from a repeat of massive financial destruction. Taxpayer-funded bailouts of too-big-to-fail banks and financial firms and their numerous violations of the law, often criminal violations. Effectively management, supervision, discipline, or resolution of too-big-to-fail banks and financial firms. Mega bank multi-trillion dollars financial assistance. Community banks assistance and more than 500 failed community banks. Downsizing too-big-to-fail banks and financial firms. The fundamental American constitutional right of equal justice under the law applicability when it comes to the mega banks. The U.S. two-tiered system of justice - too-big-to-fail banks and financial firms and everyone else. The Department of Justice (DOJ) - laggard in prosecuting crimes stemming from the financial crisis. Banking regulators and the DOJ aggressively pursuing actions against community banks, their directors, and officers with board resolutions, MOUs, C&Ds, consent orders, monetary penalties, barring individuals from banking, criminal prosecution, and other actions. No mandatory Prompt Corrective Action (PCA) capital enforcement orders against any bank larger than $30 billion in assets, yet 1,400 PCAs against community banks. Evidence of a clear double standard. Opponents of downsizing the mega banks (include their paid association cheerleaders) consistently blocking meaningful reforms and obfuscating the issue of too-big-to-fail for the benefit of large members and the detriment of everyone else. Too-big-to-fail banks, directors, officers, or employees being - too-big-to-manage, too-big-to-regulate, too-big-to-fail, too-big-to-prosecute, too-big-to-jail, too-big-to-change, and clearly too-big-to-behave --- downsize. Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by Wall Street mega banks during the financial crisis. The different/modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a one-size-fits-all approach. Disproportionate burden of banking laws and regulations on community banks. Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks. Unlevel playing field and a significant competitive disadvantage for community banks. Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies. Excessive, redundant and costly regulations. Regulatory accountability. Community banks dedicating resources to promoting economic growth. Steady increase in regulations over many decades. Regulatory threats to community banks and their communities. The Plan for Prosperity regarding: Basel III original intent. additional capital for small holding companies - modernize the Federal Reserves Policy Statement. Securities and Exchange Commission rules. reforming mortgage lending. accountability in bank exams by providing an appeals process. bank oversight and examinations - targeting risks. annual requirement for redundant privacy notices. consumer regulation - inclusive and accountable CFPB governance. arbitrary disparate impact fair lending causes of action. viability of mutual banks with new charter options. cost-benefit analysis to justify new rules. red tape in small business lending - burdensome data collection. community bank mortgage servicing. Treasury Assistant Secretary for Community Banks. subchapter S constraints. five-year loss carryback - support for lending during economic downturns. risk targeting in the Volcker Rule. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks. Credit Union Taxation and Expansion of Powers - Credit unions now indistinguishable from community banks, grown to control a significant share of the banking services market. Original business model now outdated. Credit unions strayed from founding purpose of serving individuals of modest means and with a common bond. Same financial services as community banks. Federal tax-exempt status, in exchange for serving their original mission is no longer justified. Credit unions paying their fair share of income taxes Credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L). The exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks]. The Office of Management and Budget tax expenditure analysis - tax-exemption for credit unions result in loss of tax revenues of $9.46 billion over fiscal years 2014-2018. Credit union expansion of commercial lending powers - increasing the percentage of cap on member business lending (MBL). Loan growth at the expense of tax-paying community banks. Fundamental altering the exclusive member-focused character of credit unions - a condition for their original tax exemption. Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts. The same Call Report filing requirements for credit unions as those imposed on community banks. Tax subsidy and level the playing field between credit unions and tax-paying community banks. Farm Credit System - Expansionist agenda of the Farm Credit System (FCS). FCS almost the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status. Tax advantages - unfair competitive advantage. Follow narrow historic mission - abolish or be subject to taxation and oversight and regulation. Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives. Support and cooperation of Farm Credit Administration (FCA) - FCS straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities. FCS significant systemic and taxpayer bail-out risks. The FCS (only GSE) in active competition with community banks. Public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks). Funding and tax benefits impact on community banks. FCS not following its narrow historical mission. Follow narrow mission or abolish System. Abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity. FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight. Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks. Enhanced Cyber, Data and Payment Card Security - Establish a federal data security standard and notice requirement for all entities that store consumer data comparable to the Gramm-Leach-Bliley Act (GLBA) standards that apply to community banks. Shifting the liability for all costs associated with the data breach - including fraud losses and the cost of card reissuance - to the party that caused the breach. Consumer Financial Protection Bureau Mortgage Lending and Housing Finance Reform - Imprudent mortgage lending contribution to the mortgage meltdown and the financial crisis. Community banks common sense relationship lending and not participating in abusive and predatory lending practices. Community banks thriving on the strength of their reputations and incentive to make fair and reasonable loans. No need for prescriptive regulations to compel community banks to do the right thing for their customers. Curb imprudent lending practices. Not impacting responsible community bank loan products designed to meet the diverse needs of their customers, including borrowers with special needs and circumstances, first-time homebuyers, borrowers in rural and underserved areas, and low-to-moderate income borrowers. Regulators recognition of the difference between the non-traditional lending practiced by community banks and predatory lending practiced by others. Community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas should receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs). Special accommodations for small creditors, flexibility in serving the needs of customers and communities, particularly in rural areas, and the definition of underserved areas to include economically challenged areas. Reforms to the housing GSEs to include the existence of an impartial secondary market for residential mortgages, one that is financially strong and reliable, the need for some government tie to the secondary market to ensure the continued flow of credit and market liquidity during severe economic stress, no limit to full participation by community banks, and a return of private capital. Additional reforms to include community banks access to sell loans through an independent entity; no appropriation of community bank customer data for the purpose of cross selling financial services; maintain the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market; pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed; and no further consolidation of the housing finance system. Stop aggressively compelling community banks to repurchase transferred real estate mortgages for technical violations of underwriting agreements that had no bearing on the quality of the loan at the time of underwriting. Disparate Impact Fair Lending Causes of Action - Enforcement actions by the Department of Housing and Urban Development (HUD) and the Department of Justice (DOJ) - disparate impact. Additional obligation on community banks to consider such factors as race or national origin in credit decisions, which is specifically precluded by law - untenable situation Consumer Financial Protection Bureau Reform - Community banks regulatory relief to serve unique needs of their customers and not hinder new product development and innovation. Community bank flexibility to meet the unique needs of customers and community banks additional and unnecessary regulatory requirements to prevent their serving their communities. No a one-size-fits-all approach to CFPB regulations. Community banks not enduring any additional consumer regulatory burden on top of the existing regulatory burden. Single-Director governance of the CFPB versus a five-member commission. Prudential regulators participating with the CFPB in the rule-writing process. The Financial Stability Oversight Council (FSOC) power to veto CFPB rules. Broad definition of firms that grant credit being subject to the CFPB rules, and their robust supervision and examinations. Focus of any enhanced regulation of financial products on unregulated shadow financial companies. CFPBs efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products. CFPB holding mega banks and financial firms up to the existing standards for compliance with consumer laws, rules and regulations as required by community banks. Revised definitions in the Ability-to-Repay Qualified Mortgage rules of small creditor and rural areas, and expansion of the definition of underserved areas to include economically challenged areas. De Novo Community Bank Formation - Need for newly chartered (de novo) community banks. FDIC inhibiting de novo community bank formation. FDICs current position and a one-size-fits-all supervisory policy for de novos. Federal Home Loan Bank System - The Federal Home Loan Banks (FHLBs) partnership with community banks - short-term liquidity, long-term funding and other financial products and providing lendable funds for the local communities. Maintaining the regional structure, special functions and purposes of the FHLBs. The FHLB Systems health, stability and reliability for its members. FHFAs proposed (2014) revisions to FHLB membership eligibility requirements - impact on the FHLB System and its members including, but not limited to, regulatory burden, member balance sheet management, stability of the System, and continued reliability as a funding partner, future value of FHLB membership and the implications for membership decisions; and impact on housing and community development throughout the System. The proposed rule is also contrary to the will of Congress. FHLB System reliance as the sole aggregator or securitizer of residential mortgages for community banks, and the FHFAs imposition of an ongoing housing mission asset test on community financial institutions. Excessive Intervention in Monetary Policy - The sustained record-low zero interest rate policy (ZIRP) - disproportionate impact on community banks, senior citizens and discourages savings. Record-low interest rates for five years+ does not constitute temporary intervention but long-term and harmful manipulation. The limits to what Fed monetary policy can accomplish, especially given major offsetting negative effects. Legislation - H.R. 1523 - Community Bank Access to Capital Act of 2015 (enhance community bank and thrift access to capital) (all sections) (House and Senate) H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate) H.R. 2205 and S. 961 - Data Security Act of 2015 (data breach and security, notifications, safeguards, GLBA compliance procedures) (All sections) (House and Senate) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate) Highway Trust Fund Reauthorization - (Senate versions proposed reduction of dividends paid on Federal Reserve Bank stock as pay-for) (Senate) H.R. 1941 - Financial Institutions Examination Fairness and Reform Act (regulatory examinations standards and FFIEC Ombudsman) (all sections) (House) S. 1440 and H.R. 1422 - Credit Union Residential Loan Parity Act (exclude loans to non-primary residence 1-4 family dwellings from member business lending cap) (all sections) (Senate) State of Illinois legislation - (sharing of IDFPR state bank examination reports with the Federal Home Loan Bank of Chicago) Comment Letters - Comment Letter - CFPB, grace period for enforcement and liability in the implementation, and delay in the implementation of the TRID Comment Letter - Department of Labor, proposed increase in the salary threshold for employees who are exempt from overtime mandates of the Fair Labor Standards Act Comment Letter - National Credit Union Administration, comments on proposed rulemaking for Part 723 (RIN 3133-AE37) to rewrite rules governing credit union member business lending (House and Senate) Comment Letter - FDIC, Notice of Proposed Rulemaking and request for Comments RIN 3064-AE37 to refine the deposit insurance assessment system for small depository institutions Action Alerts - H.R. 1233 and S. 812 - Community Lending Enhancement and Regulatory (CLEAR) Relief Act of 2015 (community bank regulatory relief) (all sections) (House and Senate), and H.R. 1523 and S. 1816 - Community Bank Access to Capital (enhance community bank and thrift access to capital) (all sections) (House and Senate) Highway Trust Fund Reauthorization - (Senate versions proposed reduction of dividends paid on Federal Reserve Bank stock as pay-for) (Senate) National Credit Union Administration regarding proposed rulemaking to rewrite rules governing credit union member business lending Miscellaneous - Regarding CFPB, delay in implementation of TRID and period of restrained enforcement and liability, the definition of rural and underserved areas in the QM, regulatory burden on community banks, declining number of community banks and community bank consolidation (House) Current community bank regulatory examination environment (Senate)

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate) Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by Wall Street mega banks during the financial crisis. The different modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a one-size-fits-all approach. Disproportionate burden of banking laws and regulations on community banks. Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks. Unlevel playing field and a significant competitive disadvantage for community banks. Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies. Excessive, redundant and costly regulations. Regulatory accountability. Community banks dedicating resources to promoting economic growth. Steady increase in regulations over many decades. Regulatory threats to community banks and their communities. The Plan for Prosperity regarding: Basel III original intent. additional capital for small holding companies - modernize the Federal Reserves Policy Statement. Securities and Exchange Commission rules. reforming mortgage lending. accountability in bank exams by providing an appeals process. bank oversight and examinations - targeting risks. annual requirement for redundant privacy notices. consumer regulation - inclusive and accountable CFPB governance. arbitrary disparate impact fair lending causes of action. viability of mutual banks with new charter options. cost-benefit analysis to justify new rules. red tape in small business lending - burdensome data collection. community bank mortgage servicing. Treasury Assistant Secretary for Community Banks. subchapter S constraints. five-year loss carryback - support for lending during economic downturns. risk targeting in the Volcker Rule. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks.

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate) Farm Credit System - Expansionist agenda of the Farm Credit System (FCS). FCS almost the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status. Tax advantages - unfair competitive advantage. Follow narrow historic mission - abolish or be subject to taxation and oversight and regulation. Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives. Support and cooperation of Farm Credit Administration (FCA) - FCS straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities. FCS significant systemic and taxpayer bail-out risks. The FCS (only GSE) in active competition with community banks. Public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks). Funding and tax benefits impact on community banks. FCS not following its narrow historical mission. Follow narrow mission or abolish System. Abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity. FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight. Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks. Revised definitions in the Ability-to-Repay Qualified Mortgage rules of small creditor and rural areas, and expansion of the definition of underserved areas to include economically challenged areas. (House and Senate) Comment Letters - Comment Letter - Illinois House Ways and Means Committee members, reforming tax code regarding tax subsidies for credit unions and Farm Credit System Comment Letter - Farm Credit Administration, corporate governance standards of conduct proposed rule, 12CFR Parts 650, 651, 653 and 655; RIN 3052-AC89

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate) Too-to-Fail - Reform the financial system. The severity of a future financial crisis. The perception and reality of too-big-to-fail. Taxpayer bailouts of mega banks and financial firms. Mega bank size, complexity and interconnectedness, and candidacy for future bailouts. The number of community banks falling by more than half (currently 6,200 institutions) and now represent less than one-fifth of banking professions assets. Causes of the mortgage meltdown and financial crisis. Protection of the nation and the banking profession from a repeat of massive financial destruction. Taxpayer-funded bailouts of too-big-to-fail banks and financial firms and their numerous violations of the law, often criminal violations. Effectively management, supervision, discipline, or resolution of too-big-to-fail banks and financial firms. Mega bank multi-trillion dollars financial assistance. Community banks assistance and more than 500 failed community banks. Downsizing too-big-to-fail banks and financial firms. The fundamental American constitutional right of equal justice under the law applicability when it comes to the mega banks. The U.S. two-tiered system of justice - too-big-to-fail banks and financial firms and everyone else. The Department of Justice (DOJ) - laggard in prosecuting crimes stemming from the financial crisis. Banking regulators and the DOJ aggressively pursuing actions against community banks, their directors, and officers with board resolutions, MOUs, C&Ds, consent orders, monetary penalties, barring individuals from banking, criminal prosecution, and other actions. No mandatory Prompt Corrective Action (PCA) capital enforcement orders against any bank larger than $30 billion in assets, yet 1,400 PCAs against community banks. Evidence of a clear double standard. Opponents of downsizing the mega banks (include their paid association cheerleaders) consistently blocking meaningful reforms and obfuscating the issue of too-big-to-fail for the benefit of large members and the detriment of everyone else. Too-big-to-fail banks, directors, officers, or employees being - too-big-to-manage, too-big-to-regulate, too-big-to-fail, too-big-to-prosecute, too-big-to-jail, too-big-to-change, and clearly too-big-to-behave --- downsize. Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by Wall Street mega banks during the financial crisis. The different modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a one-size-fits-all approach. Disproportionate burden of banking laws and regulations on community banks. Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks. Unlevel playing field and a significant competitive disadvantage for community banks. Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies. Excessive, redundant and costly regulations. Regulatory accountability. Community banks dedicating resources to promoting economic growth. Steady increase in regulations over many decades. Regulatory threats to community banks and their communities. The Plan for Prosperity regarding: Basel III original intent. additional capital for small holding companies - modernize the Federal Reserves Policy Statement. Securities and Exchange Commission rules. reforming mortgage lending. accountability in bank exams by providing an appeals process. bank oversight and examinations - targeting risks. annual requirement for redundant privacy notices. consumer regulation - inclusive and accountable CFPB governance. arbitrary disparate impact fair lending causes of action. viability of mutual banks with new charter options. cost-benefit analysis to justify new rules. red tape in small business lending - burdensome data collection. community bank mortgage servicing. Treasury Assistant Secretary for Community Banks. subchapter S constraints. five-year loss carryback - support for lending during economic downturns. risk targeting in the Volcker Rule. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks. Credit Union Taxation and Expansion of Powers - Credit unions now indistinguishable from community banks, grown to control a significant share of the banking services market. Original business model now outdated. Credit unions strayed from founding purpose of serving individuals of modest means and with a common bond. Same financial services as community banks. Federal tax-exempt status, in exchange for serving their original mission is no longer justified. Credit unions should pay their fair share of income taxes. Credit unions not adhering to a common bond or operating within a well-defined local community, neighborhood or rural district. Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L). The exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks]. The Office of Management and Budget tax expenditure analysis - tax-exemption for credit unions result in loss of tax revenues of $9.46 billion over fiscal years 2014-2018. Credit union expansion of commercial lending powers - increasing the percentage of assets cap on member business lending (MBL). Loan growth at the expense of tax-paying community banks. Fundamental altering the exclusive member-focused character of credit unions - a condition for their original tax exemption. Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts. The same Call Report filing requirements for credit unions as those imposed on community banks. Tax subsidy and level the playing field between credit unions and tax-paying community banks. Farm Credit System - Expansionist agenda of the Farm Credit System (FCS). FCS almost the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status. Tax advantages - unfair competitive advantage. Follow narrow historic mission - abolish or be subject to taxation and oversight and regulation. Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives. Support and cooperation of Farm Credit Administration (FCA) - FCS straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities. FCS significant systemic and taxpayer bail-out risks. The FCS (only GSE) in active competition with community banks. Public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks). Funding and tax benefits impact on community banks. FCS not following its narrow historical mission. Follow narrow mission or abolish System. Abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity. FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight. Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks. Enhanced Cyber, Data and Payment Card Security - Establish a federal data security standard and notice requirement for all entities that store consumer data comparable to the Gramm-Leach-Bliley Act (GLBA) standards that apply to community banks. Shifting the liability for all costs associated with the data breach - including fraud losses and the cost of card reissuance - to the party that caused the breach. Consumer Financial Protection Bureau Mortgage Lending and Housing Finance Reform - Imprudent mortgage lending contribution to the mortgage meltdown and the financial crisis. Community banks common sense relationship lending and not participating in abusive and predatory lending practices. Community banks thriving on the strength of their reputations and incentive to make fair and reasonable loans. No need for prescriptive regulations to compel community banks to do the right thing for their customers. Curb imprudent lending practices. Not impacting responsible community bank loan products designed to meet the diverse needs of their customers, including borrowers with special needs and circumstances, first-time homebuyers, borrowers in rural and underserved areas, and low-to-moderate income borrowers. Regulators recognition of the difference between the non-traditional lending practiced by community banks and predatory lending practiced by others. Community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas should receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs). Special accommodations for small creditors, flexibility in serving the needs of customers and communities, particularly in rural areas, and the definition of underserved areas to include economically challenged areas. Reforms to the housing GSEs to include the existence of an impartial secondary market for residential mortgages, one that is financially strong and reliable, the need for some government tie to the secondary market to ensure the continued flow of credit and market liquidity during severe economic stress, no limit in full participation by community banks, and a return of private capital. Additional reforms to include community banks access to sell loans through an independent entity; no appropriation of community bank customer data for the purpose of cross selling financial services; maintain the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market; pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed; and no further consolidation of the housing finance system. Stop aggressively compelling community banks to repurchase transferred real estate mortgages for technical violations of underwriting agreements that had no bearing on the quality of the loan at the time of underwriting. Disparate Impact Fair Lending Causes of Action - Enforcement actions by the Department of Housing and Urban Development (HUD) and the Department of Justice (DOJ) - disparate impact. Additional obligation on community banks to consider such factors as race or national origin in credit decisions, which is specifically precluded by law - untenable situation Consumer Financial Protection Bureau Reform - Community banks regulatory relief to serve unique needs of their customers and not hinder new product development and innovation. Community bank flexibility to meet the unique needs of customers and community banks additional and unnecessary regulatory requirements to prevent their serving their communities. Not a one-size-fits-all approach to CFPB regulations. Community banks not enduring any additional consumer regulatory burden on top of the existing regulatory burden. Single-Director governance of the CFPB with a five-member commission. Prudential regulators participating with the CFPB in the rule-writing process. The Financial Stability Oversight Council (FSOC) power to veto CFPB rules. Broad definition of firms that grant credit being subject to the CFPB rules, and their robust supervision and examinations. Focus of any enhanced regulation of financial products on unregulated shadow financial companies. CFPBs efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products. CFPB holding mega banks and financial firms up to the existing standards for compliance with consumer laws, rules and regulations as required by community banks. Revised definitions in the Ability-to-Repay Qualified Mortgage rules of small creditor and rural areas, and expansion of the definition of underserved areas to include economically challenged areas. De Novo Community Bank Formation - Need for newly chartered (de novo) community banks. FDIC inhibiting de novo community bank formation. FDICs current position and a one-size-fits-all supervisory policy for de novos. Federal Home Loan Bank System - The Federal Home Loan Banks (FHLBs) partnership with community banks - short-term liquidity, long-term funding and other financial products and providing lendable funds for the local communities. Maintaining the regional structure, special functions and purposes of the FHLBs. The FHLB Systems health, stability and reliability for its members. FHFAs proposed (2014) revisions to FHLB membership eligibility requirements - impact on the FHLB System and its members including, but not limited to, regulatory burden, member balance sheet management, stability of the System, and continued reliability as a funding partner, future value of FHLB membership and the implications for membership decisions; and impact on housing and community development throughout the System. The proposed rule is also contrary to the will of Congress. FHLB System reliance as the sole aggregator or securitizer of residential mortgages for community banks, and the FHFAs imposition of an ongoing housing mission asset test on community financial institutions. Excessive Intervention in Monetary Policy - The sustained record-low zero interest rate policy (ZIRP) - disproportionate impact on community banks, senior citizens and discourages savings. Record-low interest rates for five years+ does not constitute temporary intervention but long-term and harmful manipulation. The limits to what Fed monetary policy can accomplish, especially given major offsetting negative effects. Legislation - Proposed HMDA legislation - (additional data points, exempting banks provided they have less than 250 home mortgage finance transactions; exempting banks from new HMDA requirements not directly authorized by the Dodd-Frank; exempt commercial purpose, home equity lines of credit, reverse mortgages, home improvement loans and repurchased loans from HMDA requirements) (House) H.R. 650 - Preserving Access to Manufactured Housing Act of 2015 (Amends TILA to exclude mortgage originators from retailers of manufactured housing) (all sections) (House) H.R. 1731 - National Cyber Security Protection Advancement Act of 2105 (Information sharing, collaboration coordination, preparation, and security improvements and resiliency, reporting) (all sections) (House) H.R. 1560 - Protecting Cyber Networks Act (Notification procedures, defensive measures, information sharing, monitoring information systems, liability protection) (all sections) (House) S. 1484 - Financial Regulatory Improvement Act of 2015 (Title 1 community bank regulatory relief measures) (Title 1 - Sections 100-126) (Senate) S. 1206 - Too Big to Fail, Too Big to Exist Act (addressing too-big-to-fail institutions) (all sections) (Senate) Comment Letters - Comment Letter - Illinois House Ways and Means Committee members, reforming tax code regarding tax subsidies for credit unions and Farm Credit System Comment Letter - CFPB, grace period of enforcement and liability in the implementation of the TRID Comment Letter - CFPB, data service providers requirement to provide data pertaining to overdraft programs Comment Letter - Federal Reserve Bank, Office of Comptroller of the Currency, Federal Deposit Insurance Corporation, Regulatory Review under EGRPRA (tiered regulation for community banks, Prompt Corrective Action (PCA), CRA asset thresholds), Docket ID FFIEC-2014-0001 Comment Letter - Farm Credit Administration, corporate governance standards of conduct proposed rule, 12CFR Parts 650, 651, 653 and 655; RIN 3052-AC89 Action Alerts - H.R. 1233 and S. 812 - Community Lending Enhancement and Regulatory (CLEAR) Relief Act of 2015 (community bank regulatory relief) (all sections) (House and Senate) S. 1484 - Financial Regulatory Improvement Act of 2015 (Title 1 community bank regulatory relief measures) (Title 1 - Sections 100-126) (Senate) H.R. 1523 - The Community Bank Access to Capital Act (enhance community bank access to capital) (all sections) (House) S. 423 - The Privacy Notice Modernization Act (redundant privacy notice relief) (Senate)

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate) Credit Union Taxation and Expansion of Powers - Credit unions now indistinguishable from community banks, grown to control a significant share of the banking services market. Original business model now outdated. Credit unions strayed from founding purpose of serving individuals of modest means and with a common bond. Same financial services as community banks. Federal tax-exempt status, in exchange for serving their original mission is no longer justified. Credit unions should pay their fair share of income taxes. Credit unions not adhering to a common bond or operating within a well-defined local community, neighborhood or rural district. Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L). The exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks]. The Office of Management and Budget tax expenditure analysis - tax-exemption for credit unions result in loss of tax revenues of $9.46 billion over fiscal years 2014-2018. Credit union expansion of commercial lending powers - increasing the percentage of assets cap on member business lending (MBL). Loan growth at the expense of tax-paying community banks. Fundamental altering the exclusive member-focused character of credit unions - a condition for their original tax exemption. Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts. The same Call Report filing requirements for credit unions as those imposed on community banks. Tax subsidy and level the playing field between credit unions and tax-paying community banks. Farm Credit System - Expansionist agenda of the Farm Credit System (FCS). FCS almost the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status. Tax advantages - unfair competitive advantage. Follow narrow historic mission - abolish or be subject to taxation and oversight and regulation. Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives. Support and cooperation of Farm Credit Administration (FCA) - FCS straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities. FCS significant systemic and taxpayer bail-out risks. The FCS (only GSE) in active competition with community banks. Public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks). Funding and tax benefits impact on community banks. FCS not following its narrow historical mission. Follow narrow mission or abolish System. Abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity. FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight. Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks. Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by Wall Street mega banks during the financial crisis. The different modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a one-size-fits-all approach. Disproportionate burden of banking laws and regulations on community banks. Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks. Unlevel playing field and a significant competitive disadvantage for community banks. Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies. Excessive, redundant and costly regulations. Regulatory accountability. Community banks dedicating resources to promoting economic growth. Steady increase in regulations over many decades. Regulatory threats to community banks and their communities. The Plan for Prosperity regarding: Basel III original intent. additional capital for small holding companies - modernize the Federal Reserves Policy Statement. Securities and Exchange Commission rules. reforming mortgage lending. accountability in bank exams by providing an appeals process. bank oversight and examinations - targeting risks. annual requirement for redundant privacy notices. consumer regulation - inclusive and accountable CFPB governance. arbitrary disparate impact fair lending causes of action. viability of mutual banks with new charter options. cost-benefit analysis to justify new rules. red tape in small business lending - burdensome data collection. community bank mortgage servicing. Treasury Assistant Secretary for Community Banks. subchapter S constraints. five-year loss carryback - support for lending during economic downturns. risk targeting in the Volcker Rule. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks. Comment Letters - Comment Letter - Illinois House Ways and Means Committee members, reforming tax code regarding tax subsidies for credit unions and Farm Credit System

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate) Consumer Financial Protection Bureau Mortgage Lending and Housing Finance Reform - Imprudent mortgage lending contribution to the mortgage meltdown and the financial crisis. Community banks common sense relationship lending and not participate in abusive and predatory lending practices. Community banks thriving on the strength of their reputations and incentive to make fair and reasonable loans. No need for prescriptive regulations to compel community banks to do the right thing for their customers. Curb imprudent lending practices. Not impacting responsible community bank loan products designed to meet the diverse needs of their customers, including borrowers with special needs and circumstances, first-time homebuyers, borrowers in rural and underserved areas, and low-to-moderate income borrowers. Regulators recognition of the difference between the non-traditional lending practiced by community banks and predatory lending practiced by others. Community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas should receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs). Special accommodations for small creditors, flexibility in serving the needs of customers and communities, particularly in rural areas, and the definition of underserved areas to include economically challenged areas. Reforms to the housing GSEs to include the existence of an impartial secondary market for residential mortgages, one that is financially strong and reliable, the need for some government tie to the secondary market to ensure the continued flow of credit and market liquidity during severe economic stress, no limit in full participation by community banks, and a return of private capital. Additional reforms to include community banks access to sell loans through an independent entity; no appropriation of community bank customer data for the purpose of cross selling financial services; maintain the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market; pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed; and no further consolidation of the housing finance system. Stop aggressively compelling community banks to repurchase transferred real estate mortgages for technical violations of underwriting agreements that had no bearing on the quality of the loan at the time of underwriting. Disparate Impact Fair Lending Causes of Action - Enforcement actions by the Department of Housing and Urban Development (HUD) and the Department of Justice (DOJ) - disparate impact. Additional obligation on community banks to consider such factors as race or national origin in credit decisions, which is specifically precluded by law - untenable situation. Consumer Financial Protection Bureau Reform - Community banks regulatory relief to serve unique needs of their customers and not hinder new product development and innovation. Community bank flexibility to meet the unique needs of customers and community banks additional and unnecessary regulatory requirements to prevent their serving their communities. Not a one-size-fits-all approach to CFPB regulations. Community banks not enduring any additional consumer regulatory burden on top of the existing regulatory burden. Single-Director governance of the CFPB with a five-member commission. Prudential regulators participating with the CFPB in the rule-writing process. The Financial Stability Oversight Council (FSOC) power to veto CFPB rules. Broad definition of firms that grant credit being subject to the CFPB rules, and their robust supervision and examinations. Focus of any enhanced regulation of financial products on unregulated shadow financial companies. CFPBs efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products. CFPB holding mega banks and financial firms up to the existing standards for compliance with consumer laws, rules and regulations as required by community banks. Federal Home Loan Bank System - The Federal Home Loan Banks (FHLBs) partnership with community banks - short-term liquidity, long-term funding and other financial products and providing lendable funds for the local communities. Maintaining the regional structure, special functions and purposes of the FHLBs. The FHLB Systems health, stability and reliability for its members. FHFAs proposed (2014) revisions to FHLB membership eligibility requirements - impact on the FHLB System and its members including, but not limited to, regulatory burden, member balance sheet management, stability of the System, and continued reliability as a funding partner, future value of FHLB membership and the implications for membership decisions; and impact on housing and community development throughout the System. The proposed rule is also contrary to the will of Congress. FHLB System reliance as the sole aggregator or securitizer of residential mortgages for community banks, and the FHFAs imposition of an ongoing housing mission asset test on community financial institutions. Excessive Intervention in Monetary Policy - The sustained record-low zero interest rate policy (ZIRP) - disproportionate impact on community banks, senior citizens and discourages savings. Record-low interest rates for five years+ does not constitute temporary intervention but long-term and harmful manipulation. The limits to what Fed monetary policy can accomplish, especially given major offsetting negative effects. Revised definitions in the Ability-to-Repay Qualified Mortgage rules of small creditor and rural areas, and expansion of the definition of underserved areas to include economically challenged areas. (House and Senate) Proposed HMDA legislation - (additional data points, exempting banks provided they have less than 250 home mortgage finance transactions; exempting banks from new HMDA requirements not directly authorized by the Dodd-Frank; exempt commercial purpose, home equity lines of credit, reverse mortgages, home improvement loans and repurchased loans from HMDA requirements) (House) Legislation - H.R. 650 - Preserving Access to Manufactured Housing Act of 2015 (Amends TILA to exclude mortgage originators from retailers of manufactured housing) (all sections) (House) H.R. 1731 - National Cyber Security Protection Advancement Act of 2105 (Information sharing, collaboration coordination, preparation, and security improvements and resiliency, reporting) (all sections) (House) H.R. 1560 - Protecting Cyber Networks Act (Notification procedures, defensive measures, information sharing, monitoring information systems, liability protection) (all sections) (House) S. 1484 - Financial Regulatory Improvement Act of 2015 (Title 1 community bank regulatory relief measures) (Title 1 - Sections 100-126) (Senate) Comment Letters - Comment Letter - CFPB, grace period of enforcement and liability in the implementation of the TRID Comment Letter - CFPB, data service providers requirement to provide data pertaining to overdraft programs Comment Letter - Federal Reserve Bank, Office of Comptroller of the Currency, Federal Deposit Insurance Corporation, Regulatory Review under EGRPRA (tiered regulation for community banks, Prompt Corrective Action (PCA), CRA asset thresholds), Docket ID FFIEC-2014-0001 Action Alerts - S. 423 - The Privacy Notice Modernization Act (redundant privacy notice relief) (Senate) H.R. 1233 and S. 812 - Community Lending Enhancement and Regulatory (CLEAR) Relief Act of 2015 (community bank regulatory relief) (all sections) (House and Senate)

Community Bankers Association of Illinois Preliminary 2015 Federal Policy Priorities regarding - Too-Big-To-Fail Banks and Financial Firms, and Future Bailouts Tiered Regulations and Supervision for Community Banks Enhanced Security for Consumer Data (Data Breaches/Cyber security) Taxation of Credit Unions Farm Credit System Mortgage Lending Reform Housing Finance (GSE Secondary Market) Reform Tax, Accounting, and Auditing Changes Remaining Implementation of the Dodd-Frank Wall Street Reform Act (Dodd Frank or Act), Gains Made by Community Banks, Negative Effects De Novo Community Bank Formation Federal Home Loan Bank System Intervention in Monetary Policy Wall Street Insiders in Senior Administration Positions - Antonio Weiss nomination to Undersecretary of Treasury for Domestic Finance (House and Senate, CFPB, OCC, FHFA, FDIC) H.R. 37 - Promoting Job Creation and Reducing Small Business Burden Act - (Sections 301- thrift registration threshold) and Section 801 - Collateralized Loan Obligations) (House) H.R.601 - Eliminate Privacy Notice Confusion Act (all sections) Redundant privacy notices (House) Comment Letter - Federal Housing Finance Agency - FHFA Proposed Rules - Members of Federal Home Loan Banks, RIN 2590-AA39 (FHFA, FRB, FDIC, OCC, House, Senate) Comment Letter - CFPB - Amendments Relating to Small Creditors and Rural and Underserved Areas Under the Truth in Lending Act (Regulation Z) Docket No. CFPB-2015-0004 and RIN 3170-AA43 (letter one) (CFPB, House, Senate) Comment Letter - CFPB - Amendments Relating to Small Creditors and Rural and Underserved Areas Under the Truth in Lending Act (Regulation Z) Docket No. CFPB-2015-0004 and RIN 3170-AA43 (letter two) Expanded CFPB definition of underserved areas in the ATR/QM Rule to include various economically challenged areas (CFPB, House, Senate) Comment Letter - Board of Governors of the Federal Reserve System - Small Bank Holding Company Policy Statement: Capital Adequacy of Board Related Institutions; Bank Holding Companies; Savings and Loan Holding Companies; and Changes to Reporting Requirements; Docket No. R-1509 and RIN 1700-AE 30 (FRB) Comment Letter - Board of Governors of the Federal Reserve System - Regulatory Capital Rules: Interim Final Rules to Exempt Small Savings and Loan Holding Companies from Regulatory Capital Rules, Docket No. R-1508 and RIN 7100-AE 29 (FRB) Community Bankers Association of Illinois Action Alerts - Regarding FHFAs Proposed Restrictive Federal Home Loan Bank Membership Rules (FHFA) Regarding Congress Supporting Meaningful Regulatory Relief (Independent Community Bankers of Americas (ICBA) Plan for Prosperity) (House and Senate)

Community Bankers Association of Illinois Preliminary 2015 Federal Policy Priorities regarding - Farm Credit System (House and Senate, CFPB, OCC, FHFA, FDIC)

Community Bankers Association of Illinois Preliminary 2015 Federal Policy Priorities regarding - Taxation of Credit Unions Farm Credit System Mortgage Lending Reform Housing Finance (GSE Secondary Market) Reform Tax, Accounting, and Auditing Changes (House and Senate, CFPB, OCC, FHFA, FDIC)

CBAI Comment Letter - Comment Letter - Farm Credit Administration (FCA) - Funding and Fiscal Affairs, Loan Policies and Operations, and Funding Operations, Proposed Rule issued by the Farm Credit Administration, FCA-2014-0023-001 and RIN: 3052-AC84 (FCA) Comment Letter - Consumer Financial Protection Bureau (CFPB) - Home Mortgage Disclosure (Regulation C), Docket No. CFPB-2014-0019, RIN 3170-AA10 (CFPB)

Expanded CFPB definition of underserved areas in the ATR/QM Rule to include various economically challenged areas (House and Senate, CFPB) Antonio Weiss nomination to Undersecretary of Treasury for Domestic Finance (House and Senate) Subchapter S and C capital conservation buffer treatment in Basel III (House and OCC) Increase in filings of FinCEN Suspicious Activity Reports (SARs) (House) Short form Call Reports, Economic Growth Regulatory Paperwork Reduction Act (EGRPRA), banking medical marijuana enterprises, examiner/examination approach/tone/teams and timing, regulator advocacy for community banks, best practices and reputational risk, loan classifications (OCC) CBAI Comment and Association Letters - Comment Letter - Farm Credit Administration (FCA) - Funding and Fiscal Affairs, Loan Policies and Operations, and Funding Operations, Proposed Rule issued by the Farm Credit Administration, FCA-2014-0023-001 and RIN: 3052-AC84 (FCA) Comment Letter - Consumer Financial Protection Bureau (CFPB) - Home Mortgage Disclosure (Regulation C), Docket No. CFPB-2014-0019, RIN 3170-AA10 (CFPB) Association Letter - Senate Finance and Banking Committees - Antonio Weiss nomination to Undersecretary of Treasury for Domestic Finance (Senate) CBAI Action Alerts - Farm Credit Administration (FCA) - Regarding proposed rule and guidance for business, community and infrastructure loans labeled as bonds or investments (FCA) Federal Housing Finance Agency (FHFA) - Regarding proposed on-going Federal Home Loan Bank membership requirements (FHFA)

Expanded CFPB definition of underserved areas in the ATR/QM Rule to include various economically challenged areas (House and Senate, CFPB) CBAI Comment Letter - Comment Letter - Consumer Financial Protection Bureau (CFPB) - Home Mortgage Disclosure (Regulation C), Docket No. CFPB-2014-0019, RIN 3170-AA10 (CFPB) CBAI Action Alert - Federal Housing Finance Agency (FHFA) - Regarding proposed on-going Federal Home Loan Bank membership requirements (FHFA)

Community Bankers Association of Illinois (CBAI) 2014 Federal Policy Priorities - Expansion of the Farm Credit System - funding & tax advantages, expansionist agenda, competitive advantages over rural community banks, regulatory safeguards and controls, Co-Bank's $725 million participation in commitment to Verizon Communications (House and Senate)Expanded CFPBs definitions of rural and underserved areas in the ATR/QM Rule to include various economically challenged areas (House and Senate, CFPB, FHFA)

Community Bankers Association of Illinois (CBAI) 2014 Federal Policy Priorities - Downsize too-big-to-fail banks and financial firms to protect our financial system, economy, and American Taxpayers from future bailouts - downsize (restructure) too-big-to-fail (TBTF) banks and financial firms, reduce the probability and severity of future financial crisis and taxpayer bailouts, moral hazard, numerous TBTF misdeeds (abuse, fraud, manipulation and scandal),too-big-to-manage, too-big-to-regulate, too-big-to-fail, too-big-to-prosecute, too-big-to-jail, Department of Justices reluctance to prosecute TBTFs versus community banks, and Government Accountability Offices (GAO) confirmation of TBTFs funding advantages (Senate) Tiered regulation supervision and exemptions for community banks - recognition of the different business model and risks posed by TBTF banks and financial firms, one size fits all legislation and regulation, separate regulation - supervision - capital - liquidity requirements, disproportionate burden on community banks, unlevel playing field, and significant community bank competitive disadvantages Including, the qualifying threshold under the Federal Reserves Small Bank Holding Company Policy Statement from $500 million to $5 billion and allowing small savings and loan holding companies to be covered by the Policy Statement, the internal control attestation requirements of Section 404(b) of the Sarbanes Oxley Act from $75 million in market capitalization to $350 million, and savings and loan holding companies being able to take advantage of the increased Securities and Exchange Commission (SEC) shareholder registration and deregistration thresholds under the JOBS Act (Senate) Community bank regulatory relief as contained in the Independent Community Bankers of America Plan for Prosperity Including, community bank exemption from certain mortgage reforms to support the housing recovery, redundant annual privacy notices, municipal advisor registration burdens to help serve local governments, Assistant Treasury Secretary for Community Banks, CFPBs more balanced regulations, improved accountability in bank exams with a workable appeals process, accounting and auditing expenses for publicly traded institutions, mutual bank new charter and dividend rules, rigorous and quantitative justification of new rules, additional capital for small bank holding companies, red tape in small-business lending, capital formation and reforming Subchapter S corporation regulations, and extending the net-operating-loss carry-back (Senate) Enhanced security for consumer data (data breaches) - responsible parties responsibility for fraud losses and the cost of mitigation, sharing of information, and a national standard for notification, community banks bearing the majority of fraud losses and reissuance costs, retailers responsibility to protect sensitive customer data (Senate) Expanded powers for tax-exempt credit unions - outdated original business model and straying from founding purpose, federal tax-exemption status, expansion of powers, level the playing field between community banks and credit unions, regulatory requirements including the Community Reinvestment Act (CRA) Including, expanded lending powers by increasing percentage of asset cap on business lending, and raising capital from outside investors (House and Senate) Expansion of the Farm Credit System - funding & tax advantages, expansionist agenda, competitive advantages over rural community banks, regulatory safeguards and controls, Co-Banks $725 million participation in commitment to Verizon Communications (House and Senate) Mortgage lending reforms - imprudent lending practices, impacting responsible lenders and loan products, meeting the diverse needs of community bank customers and their communities, differences between non-traditional versus predatory lending practices, exemption of community bank mortgage loans held in portfolio, restrictions on balloon mortgages and escrow requirements, prepayment penalties, originator compensation, limited credit availability Including, Qualified Mortgage (QM) status from the CFPBs Ability-to-Repay rules for loans originated and held in portfolio by community banks, balloon mortgages regardless of pricing, use of rural and underserved designations for QM eligibility for community banks and greatly expanding the definition of each, annual loan origination and asset threshold limits for small creditors, small servicer exemption for loans held in portfolio, community banks exemption from escrow requirements for loans held in portfolio and for small dollar amount loans, proposed adoption of the QM definition for Qualified Residential Mortgages (QRM) that would not require a high down-payment requirement (Senate)Housing Finance (GSE Secondary Market) Reform - Fannie Mae/Freddie Mac/FHFA unsustainable long-term conservatorship, community bank access to an impartial secondary market for residential mortgage loans, financial stable and reliable, government tie to secondary market (continued flow of credit and market liquidity), aggressive repurchase requests of transferred residential mortgages for technical violations Including, selling loans through an independent entity that does not compete with community banks, no appropriation of community bank customer data for the purpose of cross selling financial services, the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market, pricing of any governmental guaranties, fairness and equality to all participants regardless of volume of loans guaranteed, and further consolidation of housing finance system that would result in several mega banks and financial firms dominating the market (Senate) Tax, accounting and auditing changes - community bank focus supporting robust economic activity, savings & investments, accommodation/exemption for community banks, undue regulatory burden or cost on community banks Including, tax reform that preserves the pass-through option, including the Subchapter S corporation and the ability of business borrowers to deduct interest, taxation of capital gains and dividends held in parity and at a preferential rate, tax-exempt status of interest paid on municipal bonds together with an increase in the Bank Qualified (BQ) annual threshold to $30 million and indexed for inflation, the ability of business and mortgage borrowers to deduct interest without further limitations must also be preserved, changes to the tax laws that disadvantage one form of corporate entity versus another should include a phase-in period and an amnesty to allow for a penalty-free corporate conversion, S corporation banks ability to raise capital to be enhanced by giving them the ability to issue preferred stock, increasing their shareholder limits and allowing new IRA shareholder investments, end to the tax subsidies for credit unions and the FCS lenders, community banks amortizing CRE losses over 10 years (versus in the year in which they are taken), capital standards that recognize the loss-absorbing abilities of the entire amount of the Allowance for Loan and Lease Losses (ALLL), the 1.25% ALLL disallowance (for regulatory capital purposes) should be eliminated which would encourage banks to reserve more and would strengthen capital positions, the work of the Financial Accounting Foundations Private Company Council to seek recognition, measurement and disclosure alternatives for small private companies including non-public community banks. Including, Financial Accounting Standard Boards (FASB) proposed expected loss model requiring community banks to develop costly complex cash flow models for loans and investment securities to generate expected losses over the lives of these assets where implementing this proposal will be to frontload loss recognition which would harm both community bank earnings and capital, FASBs proposal to restrict the ability of community banks to classify mortgage loans and investment securities at amortized cost when their intent is to collect contractual cash flows which is based on the exit price of a loan or security and on the current value in a non-distressed market and which would require costly robust pricing engines and complex valuation methodologies to satisfy the standard, FASBs proposal to require extensive liquidity risk and interest rate risk footnote disclosures that would be required to be audited which would undermine the work of the prudential regulators whose job entails assessing the safety and soundness of community banks including an assessment of liquidity and interest rate risk, and new bank specific fees or punitive tax levies specifically targeting the financial service sector (Senate) Remaining Implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act Including, rein in Significantly Important Financial Institution (SIFI) with enhanced prudential standards and rigorous focused regulation, higher capital requirements, capital surcharges, concentration limits, liquidity requirements, orderly liquidation rules, credible contingency resolution plan, shielding community banks from the Dodd-Frank required increase in the deposit insurance fund reserve ratio from 1.15% to 1.35%, Volcker Rules prohibition on propriety trading and investment in and sponsorship of hedge funds and private equity funds, effectively exempting community banks Including, ensure the Consumer Financial Protection Bureau (CFPB) focuses on large banks, financial firms and shadow financial companies, holding the mega banks and financial firms up to the same high standards for compliance with consumer laws as required and attained by community banks, governance (single Director versus five member commission), prudential regulators participation with CFPB in the rule writing process, FSOC veto of CFPB rules, CFPB exemption authorityregarding community banks, revision in the definitions of rural and underserved areas in the Ability to Repays Qualified Mortgage (QM) rules, consistent and transparent standards in the evaluation of community bank fair lending standards, disparate impact and unintentional discrimination (Senate) De novo community bank formation - need to maintain growing, vibrant & evolving banking profession, Federal Deposit Insurance Corporations (FDIC) actively inhibiting de novo community bank formation, inappropriate and restrictive one-size-fits-all supervisory policy (Senate) Maintain the Federal Home Loan Bank (FHLB)System - strong partnership with community banks, healthy, stable & reliable source of funding for community banks, FHLBs should not be the sole aggregators for residential mortgages for community banks in the reform of the housing GSEs, preservation of the FHLBs special functions and purposes (Senate) Excessive (Federal Reserve) intervention in monetary policy - significant drag on community banks net interest margins and earnings, limits on what monetary policy can accomplish, impact on community banks, savers and senior citizens (Senate) ***** S. 798 Terminating Bailouts for Taxpayers Fairness Act of 2013 (capital requirements, Basel III, and community bank regulatory relief) (all sections) (House and Senate) H.R. 749 Privacy Notice Act (redundant privacy notice regulatory relief) (all sections) (House and Senate) S. 635 Privacy Act Notice Modernization Act of 2013 (redundant privacy notice regulatory relief) (all sections) (House and Senate) H.R. 1750 CLEAR Relief Act of 2013 (community lending enhancement and regulatory relief) (all sections) (House and Senate) S. 1349 CLEAR Relief Act (community lending enhancement and regulatory relief) (all sections) (House and Senate) H.R. 1553 Financial Institutions Fairness Act (regulatory examinations standards and FFIEC Ombudsman) (all sections) (House and Senate) S. 727 Financial Institutions Fairness Act (regulatory examination standards and FFIEC Ombudsman) (all sections) (House and Senate) S. 2252 Community Bank Preservation Act of 2014 (Federal Reserve Board to include one member with small bank supervisory experience) (all sections) (Senate) H.R. 4986 End Operation Choke Point Act of 2014 (prohibits federal regulators from pressuring insured depository institutions from dealing with legal and licensed businesses) (all sections) (House and Senate) H.R. 688 Credit Union Small Business Jobs Creation Act (increase member business lending percentage of capital) (all sections) (House and Senate) S. 968 Small Business lending Enhancement Act of 2013 (increase member business lending percentage of capital) (all sections) (House and Senate) H.R. 719 Capital Access for Small business and Jobs Act (capital raising from outside investors) (all sections) (House and Senate) Expanded CFPBs definitions of rural and underserved areas in the ATR/QM Rule to include various economically challenged areas (House and Senate, CFPB, FHFA)Reform of the Housing GSEs regarding: consolidation of the housing finance system, equal and direct access to the secondary market regardless of loan volume, loan pricing, right to service loans, appropriation of customer data, government footprint and private capital in the market (House and Senate) Enhanced security for consumer data (data breaches) - responsible parties responsibility for fraud losses and the cost of mitigation, sharing of information, and a national standard for notification, community banks bearing the majority of fraud losses and reissuance costs, retailers responsibility to protect sensitive customer data (House and Senate) CBAI Comment and Association Letters Comment Letter CFPB Amendment to the Annual Privacy Notice Requirement under Gramm-Leach-Bliley Act (Regulation P) Docket No. CFPB-2014-0010/RIN 3170-AA39 Associations Letter CFPB ATR/QM Rule and escrow requirements for higher-priced loans regarding loans held in portfolio for the life of the loan and automatic QM safe harbor status and exemption from the escrow requirements (for higher-priced loans) Comment letter OCC, Federal Reserve Board, FDIC Regulatory Review under Economic Growth and Regulatory Paperwork Reduction Act of 1996 (EGRPRA), Docket ID FFIEC-2014-0001, Docket No. OP-1491 regarding: tiered regulation, de novo bank formation, Call Report (regulatory relief), Small Bank Holding Company Policy Statement thresholds Comment Letter FHFA FHFA Proposed Rule members of Federal Home Loan Banks, RIN 2590-AA39 (membership eligibility requirements) CBAI Action Alerts FFIEC, FDIC, OCC, Federal Reserve Board Petition to streamline Call Report requirements

Community Bankers Association of Illinois (CBAI) 2014 Federal Policy Priorities - Downsize too-big-to-fail banks and financial firms to protect our financial system, economy, and American Taxpayers from future bailouts - downsize (restructure) too-big-to-fail (TBTF) banks and financial firms, reduce the probability and severity of future financial crisis and taxpayer bailouts, moral hazard, numerous TBTF misdeeds (abuse, fraud, manipulation and scandal),too-big-to-manage, too-big-to-regulate, too-big-to-fail, too-big-to-prosecute, too-big-to-jail, Department of Justices reluctance to prosecute TBTFs versus community banks, and Government Accountability Offices (GAO) confirmation of TBTFs funding advantages (Senate) Tiered regulation supervision and exemptions for community banks - recognition of the different business model and risks posed by TBTF banks and financial firms, one size fits all legislation and regulation, separate regulation - supervision - capital - liquidity requirements, disproportionate burden on community banks, unlevel playing field, and significant community bank competitive disadvantages Including, the qualifying threshold under the Federal Reserves Small Bank Holding Company Policy Statement from $500 million to $5 billion and allowing small savings and loan holding companies to be covered by the Policy Statement, the internal control attestation requirements of Section 404(b) of the Sarbanes Oxley Act from $75 million in market capitalization to $350 million, and savings and loan holding companies being able to take advantage of the increased Securities and Exchange Commission (SEC) shareholder registration and deregistration thresholds under the JOBS Act (Senate) Community bank regulatory relief as contained in the Independent Community Bankers of America Plan for Prosperity Including, community bank exemption from certain mortgage reforms to support the housing recovery, redundant annual privacy notices, municipal advisor registration burdens to help serve local governments, Assistant Treasury Secretary for Community Banks, CFPBs more balanced regulations, improved accountability in bank exams with a workable appeals process, accounting and auditing expenses for publicly traded institutions, mutual bank new charter and dividend rules, rigorous and quantitative justification of new rules, additional capital for small bank holding companies, red tape in small-business lending, capital formation and reforming Subchapter S corporation regulations, and extending the net-operating-loss carry-back (Senate) Enhanced security for consumer data (data breaches) - responsible parties responsibility for fraud losses and the cost of mitigation, sharing of information, and a national standard for notification, community banks bearing the majority of fraud losses and reissuance costs, retailers responsibility to protect sensitive customer data (Senate) Expanded powers for tax-exempt credit unions - outdated original business model and straying from founding purpose, federal tax-exemption status, expansion of powers, level the playing field between community banks and credit unions, regulatory requirements including the Community Reinvestment Act (CRA) Including, expanded lending powers by increasing percentage of asset cap on business lending, and raising capital from outside investors (House and Senate) Expansion of the Farm Credit System - funding & tax advantages, expansionist agenda, competitive advantages over rural community banks, regulatory safeguards and controls, Co-Banks $725 million participation in commitment to Verizon Communications (House and Senate) Mortgage lending reforms - imprudent lending practices, impacting responsible lenders and loan products, meeting the diverse needs of community bank customers and their communities, differences between non-traditional versus predatory lending practices, exemption of community bank mortgage loans held in portfolio, restrictions on balloon mortgages and escrow requirements, prepayment penalties, originator compensation, limited credit availability Including, Qualified Mortgage (QM) status from the CFPBs Ability-to-Repay rules for loans originated and held in portfolio by community banks, balloon mortgages regardless of pricing, use of rural and underserved designations for QM eligibility for community banks and greatly expanding the definition of each, annual loan origination and asset threshold limits for small creditors, small servicer exemption for loans held in portfolio, community banks exemption from escrow requirements for loans held in portfolio and for small dollar amount loans, proposed adoption of the QM definition for Qualified Residential Mortgages (QRM) that would not require a high down-payment requirement (Senate)Housing Finance (GSE Secondary Market) Reform - Fannie Mae/Freddie Mac/FHFA unsustainable long-term conservatorship, community bank access to an impartial secondary market for residential mortgage loans, financial stable and reliable, government tie to secondary market (continued flow of credit and market liquidity), aggressive repurchase requests of transferred residential mortgages for technical violations Including, selling loans through an independent entity that does not compete with community banks, no appropriation of community bank customer data for the purpose of cross selling financial services, the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market, pricing of any governmental guaranties, fairness and equality to all participants regardless of volume of loans guaranteed, and further consolidation of housing finance system that would result in several mega banks and financial firms dominating the market (Senate) Tax, accounting and auditing changes - community bank focus supporting robust economic activity, savings & investments, accommodation/exemption for community banks, undue regulatory burden or cost on community banks Including, tax reform that preserves the pass-through option, including the Subchapter S corporation and the ability of business borrowers to deduct interest, taxation of capital gains and dividends held in parity and at a preferential rate, tax-exempt status of interest paid on municipal bonds together with an increase in the Bank Qualified (BQ) annual threshold to $30 million and indexed for inflation, the ability of business and mortgage borrowers to deduct interest without further limitations must also be preserved, changes to the tax laws that disadvantage one form of corporate entity versus another should include a phase-in period and an amnesty to allow for a penalty-free corporate conversion, S corporation banks ability to raise capital to be enhanced by giving them the ability to issue preferred stock, increasing their shareholder limits and allowing new IRA shareholder investments, end to the tax subsidies for credit unions and the FCS lenders, community banks amortizing CRE losses over 10 years (versus in the year in which they are taken), capital standards that recognize the loss-absorbing abilities of the entire amount of the Allowance for Loan and Lease Losses (ALLL), the 1.25% ALLL disallowance (for regulatory capital purposes) should be eliminated which would encourage banks to reserve more and would strengthen capital positions, the work of the Financial Accounting Foundations Private Company Council to seek recognition, measurement and disclosure alternatives for small private companies including non-public community banks. Including, Financial Accounting Standard Boards (FASB) proposed expected loss model requiring community banks to develop costly complex cash flow models for loans and investment securities to generate expected losses over the lives of these assets where implementing this proposal will be to frontload loss recognition which would harm both community bank earnings and capital, FASBs proposal to restrict the ability of community banks to classify mortgage loans and investment securities at amortized cost when their intent is to collect contractual cash flows which is based on the exit price of a loan or security and on the current value in a non-distressed market and which would require costly robust pricing engines and complex valuation methodologies to satisfy the standard, FASBs proposal to require extensive liquidity risk and interest rate risk footnote disclosures that would be required to be audited which would undermine the work of the prudential regulators whose job entails assessing the safety and soundness of community banks including an assessment of liquidity and interest rate risk, and new bank specific fees or punitive tax levies specifically targeting the financial service sector (Senate) Remaining Implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act Including, rein in Significantly Important Financial Institution (SIFI) with enhanced prudential standards and rigorous focused regulation, higher capital requirements, capital surcharges, concentration limits, liquidity requirements, orderly liquidation rules, credible contingency resolution plan, shielding community banks from the Dodd-Frank required increase in the deposit insurance fund reserve ratio from 1.15% to 1.35%, Volcker Rules prohibition on propriety trading and investment in and sponsorship of hedge funds and private equity funds, effectively exempting community banks Including, ensure the Consumer Financial Protection Bureau (CFPB) focuses on large banks, financial firms and shadow financial companies, holding the mega banks and financial firms up to the same high standards for compliance with consumer laws as required and attained by community banks, governance (single Director versus five member commission), prudential regulators participation with CFPB in the rule writing process, FSOC veto of CFPB rules, CFPB exemption authorityregarding community banks, revision in the definitions of rural and underserved areas in the Ability to Repays Qualified Mortgage (QM) rules, consistent and transparent standards in the evaluation of community bank fair lending standards, disparate impact and unintentional discrimination (Senate) De novo community bank formation - need to maintain growing, vibrant & evolving banking profession, Federal Deposit Insurance Corporations (FDIC) actively inhibiting de novo community bank formation, inappropriate and restrictive one-size-fits-all supervisory policy (Senate) Maintain the Federal Home Loan Bank (FHLB)System - strong partnership with community banks, healthy, stable & reliable source of funding for community banks, FHLBs should not be the sole aggregators for residential mortgages for community banks in the reform of the housing GSEs, preservation of the FHLBs special functions and purposes (Senate) Excessive (Federal Reserve) intervention in monetary policy - significant drag on community banks net interest margins and earnings, limits on what monetary policy can accomplish, impact on community banks, savers and senior citizens (Senate) ***** S. 798 Terminating Bailouts for Taxpayers Fairness Act of 2013 (capital requirements, Basel III, and community bank regulatory relief) (all sections) (House and Senate) H.R. 749 Privacy Notice Act (redundant privacy notice regulatory relief) (all sections) (House and Senate) S. 635 Privacy Act Notice Modernization Act of 2013 (redundant privacy notice regulatory relief) (all sections) (House and Senate) H.R. 1750 CLEAR Relief Act of 2013 (community lending enhancement and regulatory relief) (all sections) (House and Senate) S. 1349 CLEAR Relief Act (community lending enhancement and regulatory relief) (all sections) (House and Senate) H.R. 1553 Financial Institutions Fairness Act (regulatory examinations standards and FFIEC Ombudsman) (all sections) (House and Senate) S. 727 Financial Institutions Fairness Act (regulatory examination standards and FFIEC Ombudsman) (all sections) (House and Senate) S. 2252 Community Bank Preservation Act of 2014 (Federal Reserve Board to include one member with small bank supervisory experience) (all sections) (Senate) H.R. 4986 End Operation Choke Point Act of 2014 (prohibits federal regulators from pressuring insured depository institutions from dealing with legal and licensed businesses) (all sections) (House and Senate) H.R. 688 Credit Union Small Business Jobs Creation Act (increase member business lending percentage of capital) (all sections) (House and Senate) S. 968 Small Business lending Enhancement Act of 2013 (increase member business lending percentage of capital) (all sections) (House and Senate) H.R. 719 Capital Access for Small business and Jobs Act (capital raising from outside investors) (all sections) (House and Senate) Expanded CFPBs definitions of rural and underserved areas in the ATR/QM Rule to include various economically challenged areas (House and Senate, CFPB, FHFA)Reform of the Housing GSEs regarding: consolidation of the housing finance system, equal and direct access to the secondary market regardless of loan volume, loan pricing, right to service loans, appropriation of customer data, government footprint and private capital in the market (House and Senate) Enhanced security for consumer data (data breaches) - responsible parties responsibility for fraud losses and the cost of mitigation, sharing of information, and a national standard for notification, community banks bearing the majority of fraud losses and reissuance costs, retailers responsibility to protect sensitive customer data (House and Senate) CBAI Comment and Association Letters Comment Letter CFPB Amendment to the Annual Privacy Notice Requirement under Gramm-Leach-Bliley Act (Regulation P) Docket No. CFPB-2014-0010/RIN 3170-AA39 Associations Letter CFPB ATR/QM Rule and escrow requirements for higher-priced loans regarding loans held in portfolio for the life of the loan and automatic QM safe harbor status and exemption from the escrow requirements (for higher-priced loans) Comment letter OCC, Federal Reserve Board, FDIC Regulatory Review under Economic Growth and Regulatory Paperwork Reduction Act of 1996 (EGRPRA), Docket ID FFIEC-2014-0001, Docket No. OP-1491 regarding: tiered regulation, de novo bank formation, Call Report (regulatory relief), Small Bank Holding Company Policy Statement thresholds Comment Letter FHFA FHFA Proposed Rule members of Federal Home Loan Banks, RIN 2590-AA39 (membership eligibility requirements) CBAI Action Alerts FFIEC, FDIC, OCC, Federal Reserve Board Petition to streamline Call Report requirements

Community Bankers Association of Illinois (CBAI) 2014 Federal Policy Priorities - Mortgage lending reforms - imprudent lending practices, impacting responsible lenders and loan products, meeting the diverse needs of community bank customers and their communities, differences between non-traditional versus predatory lending practices, exemption of community bank mortgage loans held in portfolio, restrictions on balloon mortgages and escrowrequirements, prepayment penalties, originator compensation, limited credit availability Including, Qualified Mortgage (QM) status from the CFPBs Ability-to-Repay rules for loans originated and held in portfolio by community banks, balloon mortgages regardless of pricing, use of rural and underserved designations for QM eligibility for community banks and greatly expanding the definition of each, annual loan origination and asset threshold limits for small creditors, small servicer exemption for loans held in portfolio, community banks exemption from escrow requirements for loans held in portfolio and for small dollar amount loans, proposed adoption of the QM definition for Qualified Residential Mortgages (QRM) that would not require a high down-payment requirement (Senate) Housing Finance (GSE Secondary Market) Reform - Fannie Mae/Freddie Mac/FHFA unsustainable long-term conservatorship, community bank access to an impartial secondary market for residential loans, financial stable and reliable, government tie to secondary market (continued flow of credit and market liquidity), aggressive repurchase requests of transferred residential mortgages for technical violations Including, selling loans through an independent entity that does not compete with community banks, no appropriation of community bank customer data for the purpose of cross selling financial services, the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market, pricing of any governmental guaranties, fairness and equality to all participants regardless of volume of loans guaranteed, and further consolidation of housing finance system that would result in several mega banks and financial firms dominating the market (Senate) Enhanced security for consumer data (data breaches) - responsible parties responsibility for fraud losses and the cost of mitigation, sharing of information, and a national standard for notification, community banks bearing the majority of fraud losses and reissuance costs, retailers responsibility to protect sensitive customer data (House and Senate) Remaining Implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act Including, ensure the Consumer Financial Protection Bureau (CFPB) focuses on large banks, financial firms and shadow financial companies, holding the mega banks and financial firms up to the same high standards for compliance with consumer laws as required and attained by community banks, governance (single Director versus five member commission), prudential regulators participation with CFPB in the rule writing process, FSOC veto of CFPB rules, CFPB exemption authority regarding community banks, revision in the definitions of rural and underserved areas in the Ability to Repays Qualified Mortgage (QM) rules, consistent and transparent standards in the evaluation of community bank fair lending standards, disparate impact and unintentional discrimination (Senate) Expanded CFPBs definitions of rural and underserved areas in the ATR/QM Rule to include various economically challenged areas (House and Senate, CFPB, FHFA) Reform of the Housing GSEs regarding: consolidation of the housing finance system, equal and direct access to the secondary market regardless of loan volume, loan pricing, right to service loans, appropriation of customer data, government footprint and private capital in the market (House and Senate) H.R. 749 Privacy Notice Act (redundant privacy notice regulatory relief) (all sections) (House and Senate) S. 635 Privacy Act Notice Modernization Act of 2013 (redundant privacy notice regulatory relief) (all sections) (House and Senate) H.R. 1750 CLEAR Relief Act of 2013 (community lending enhancement and regulatory relief) (all sections) (House and Senate) S. 1349 CLEAR Relief Act (community lending enhancement and regulatory relief) (all sections) (House and Senate)CBAI Comment and Association Letters - Comment Letter CFPB Amendment to the Annual Privacy Notice Requirement under Gramm-Leach-Bliley Act (Regulation P) Docket No. CFPB-2014-0010/RIN 3170-AA39 Associations Letter CFPB ATR/QM Rule and escrow requirements for higher-priced loans regarding loans held in portfolio for the life of the loan and automatic QM safe harbor status and exemption from the escrow requirements (for higher-priced loans)

Community Bankers Association of Illinois (CBAI) 2014 Federal Policy Priorities - Expansion of the Farm Credit System - funding & tax advantages, expansionist agenda, competitive advantages over rural community banks, regulatory safeguards and controls, Co-Bank's $725 million participation in commitment to Verizon Communications (House and Senate)Revision in the CFPBs definitions of rural and underserved areas in the Ability to Repays Qualified Mortgage (QM) rules (House and Senate)

Community Bankers Association of Illinois (CBAI) 2014 Federal Policy Priorities - Expanded powers for tax-exempt credit unions - outdated original business model and straying from founding purpose, federal tax-exemption status, expansion of powers, level the playing field between community banks and credit unions, regulatory requirements including the Community Reinvestment Act (CRA)Including, expanded lending powers by increasing percentage of asset cap on business lending, and raising capital from outside investors (House and Senate) Expansion of the Farm Credit System - funding & tax advantages, expansionist agenda, competitive advantages over rural community banks, regulatory safeguards and controls, Co-Banks $725 million participation in commitment to Verizon Communications (House and Senate) Tax, accounting and auditing changes - community bank focus supporting robust economic activity, savings & investments, accommodation/exemption for community banks, undue regulatory burden or cost on community banks Including, tax reform that preserves the pass-through option, including the Subchapter S corporation and the ability of business borrowers to deduct interest, taxation of capital gains and dividends held in parity and at a preferential rate, tax-exempt status of interest paid on municipal bonds together with an increase in the Bank Qualified (BQ) annual threshold to $30 million and indexed for inflation, the ability of business and mortgage borrowers to deduct interest without further limitations must also be preserved, changes to the tax laws that disadvantage one form of corporate entity versus another should include a phase-in period and an amnesty to allow for a penalty-free corporate conversion, S corporation banks ability to raise capital to be enhanced by giving them the ability to issue preferred stock, increasing their shareholder limits and allowing new IRA shareholder investments, end to the tax subsidies for credit unions and the FCS lenders, community banks amortizing CRE losses over 10 years (versus in the year in which they are taken), capital standards that recognize the loss-absorbing abilities of the entire amount of the Allowance for Loan and Lease Losses (ALLL), the 1.25% ALLL disallowance (for regulatory capital purposes) should be eliminated which would encourage banks to reserve more and would strengthen capital positions, the work of the Financial Accounting Foundations Private Company Council to seek recognition, measurement and disclosure alternatives for small private companies including non-public community banks. Including, Financial Accounting Standard Boards (FASB) proposed expected loss model requiring community banks to develop costly complex cash flow models for loans and investment securities to generate expected losses over the lives of these assets where implementing this proposal will be to frontload loss recognition which would harm both community bank earnings and capital, FASBs proposal to restrict the ability of community banks to classify mortgage loans and investment securities at amortized cost when their intent is to collect contractual cash flows which is based on the exit price of a loan or security and on the current value in a non-distressed market and which would require costly robust pricing engines and complex valuation methodologies to satisfy the standard, FASBs proposal to require extensive liquidity risk and interest rate risk footnote disclosures that would be required to be audited which would undermine the work of the prudential regulators whose job entails assessing the safety and soundness of community banks including an assessment of liquidity and interest rate risk, and new bank specific fees or punitive tax levies specifically targeting the financial service sector (House and Senate) ***** H.R. 688 Credit Union Small Business Job Creation Act (credit union member business lending cap) (all sections) (House and Senate) H.R. 719 Capital Access for Small Business and Jobs Act (credit union capital) (all sections) (House and Senate)

Community Bankers Association of Illinois (CBAI) 2014 Federal Policy Priorities - Community bank regulatory relief as contained in the Independent Community Bankers of America Plan for Prosperity Including, community bank exemption from certain mortgage reforms to support the housing recovery, redundant annual privacy notices, municipal advisor registration burdens to help serve local governments,Assistant Treasury Secretary for Community Banks, CFPBs more balanced regulations, improved accountability in bank exams with a workable appeals process, accounting and auditing expenses for publicly traded institutions, mutual bank new charter and dividend rules, rigorous and quantitative justification of new rules, additional capital for small bank holding companies, red tape in small-business lending, capital formation and reforming Subchapter S corporation regulations, and extending the net-operating-loss carry-back (House and Senate)

Community Bankers Association of Illinois (CBAI) 2014 Federal Policy Priorities - Mortgage lending reforms - imprudent lending practices, impacting responsible lenders and loan products, meeting the diverse needs of community bank customers and their communities, differences between non-traditional versus predatory lending practices, exemption of community bank mortgage loans held in portfolio, restrictions on balloon mortgages and escrow requirementsprepayment penalties, originator compensation, limited credit availability Including, Qualified Mortgage (QM) status from the CFPBs Ability-to-Repay rules for loans originated and held in portfolio by community banks, balloon mortgages regardless of pricing, use of rural and underserved designations for QM eligibility for community banks and greatly expanding the definition of each, annual loan origination and asset threshold limits for small creditors, small servicer exemption for loans held in portfolio, community banks exemption from escrow requirements for loans held in portfolio and for small dollar amount loans, proposed adoption of the QM definition for Qualified Residential Mortgages (QRM) that would not require a high down-payment requirement (House and Senate) Housing Finance (GSE Secondary Market) Reform - Fannie Mae/Freddie Mac/FHFA unsustainable long-term conservatorship, community bank access to an impartial secondary market for residential loans, financial stable and reliable, government tie to secondary market (continued flow of credit and market liquidity), aggressive repurchase requests of transferred residential mortgages for technical violations Including, selling loans through an independent entity that does not compete with community banks, no appropriation of community bank customer data for the purpose of cross selling financial services, the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market, pricing of any governmental guaranties, fairness and equality to all participants regardless of volume of loans guaranteed, and further consolidation of housing finance system that would result in several mega banks and financial firms dominating the market (House and Senate) Enhanced security for consumer data (data breaches) - responsible parties responsibility for fraud losses and the cost of mitigation, sharing of information, and a national standard for notification, community banks bearing the majority of fraud losses and reissuance costs, retailers responsibility to protect sensitive customer data (House and Senate) Remaining Implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act Including, ensure the Consumer Financial Protection Bureau (CFPB) focuses on large banks, financial firms and shadow financial companies, holding the mega banks and financial firms up to the same high standards for compliance with consumer laws as required and attained by community banks, governance (single Director versus five member commission), prudential regulators participation with CFPB in the rule writing process, FSOC veto of CFPB rules, CFPB exemption authority regarding community banks, revision in the definitions of rural and underserved areas in the Ability to Repays Qualified Mortgage (QM) rules, consistent and transparent standards in the evaluation of community bank fair lending standards, disparate impact and unintentional discrimination (House and Senate) ***** S. 635 Privacy Act Notice Modernization Act of 2013 (redundant privacy notice regulatory relief) (all sections) (Senate) H.R. 1750 CLEAR Relief Act of 2013 (community lending enhancement and regulatory relief) (all sections) (House)CBAI Comment Letters - Comment Letter CFPB Advanced Notice of Proposed Rulemaking, Debt Collection (Regulation F), Docket No. CFPB-2013-0033-0001, RIN 3170-AA41 Comment Letter FHFA Fannie Mae and Freddie Mac Loan Purchase Limits: Request for Public Input on Implementation Issues No. 2013-N-18 CBAI Action Alerts H.R. 4521 Community Institution Mortgage Relief Act (exempt community bank portfolio loans from new escrow requirements and raise the small services exemption) (all sections) (House) H.R. 4466 Financial Regulatory Clarity Act (requires federal regulators to consider whether proposed regulations are duplicative or inconsistent with existing regulations) (all sections) (House) H.R. 2673 Portfolio Lending and Mortgage Access Act (any residential mortgage held in portfolio by the originator is a Qualified Mortgage) (all sections) (House)

Community Bankers Association of Illinois (CBAI) 2014 Federal Policy Priorities - Downsize too-big-to-fail banks and financial firms to protect our financial system, economy, and American Taxpayers from future bailouts - downsize (restructure) too-big-to-fail (TBTF) banks and financial firms, reduce the probability and severity of future financial crisis and taxpayer bailouts, moral hazard, numerous TBTF misdeeds (abuse, fraud, manipulation and scandal),too-big-to-manage, too-big-to-regulate, too-big-to-fail, too-big-to-prosecute, too-big-to-jail, Department of Justices reluctance to prosecute TBTFs versus community banks, and Government Accountability Offices (GAO) confirmation of TBTFs funding advantages (House and Senate) Tiered regulation supervision and exemptions for community banks - recognition of the different business model and risks posed by TBTF banks and financial firms, one size fits all legislation and regulation, separate regulation - supervision - capital - liquidity requirements, disproportionate burden on community banks, unlevel playing field, and significant community bank competitive disadvantages Including, the qualifying threshold under the Federal Reserves Small Bank Holding Company Policy Statement from $500 million to $5 billion and allowing small savings and loan holding companies to be covered by the Policy Statement, the internal control attestation requirements of Section 404(b) of the Sarbanes Oxley Act from $75 million in market capitalization to $350 million, and savings and loan holding companies being able to take advantage of the increased Securities and Exchange Commission (SEC) shareholder registration and deregistration thresholds under the JOBS Act (House and Senate) Community bank regulatory relief as contained in the Independent Community Bankers of America Plan for Prosperity Including, community bank exemption from certain mortgage reforms to support the housing recovery, redundant annual privacy notices, municipal advisor registration burdens to help serve local governments, Assistant Treasury Secretary for Community Banks, CFPBs more balanced regulations, improved accountability in bank exams with a workable appeals process, accounting and auditing expenses for publicly traded institutions, mutual bank new charter and dividend rules, rigorous and quantitative justification of new rules, additional capital for small bank holding companies, red tape in small-business lending, capital formation and reforming Subchapter S corporation regulations, and extending the net-operating-loss carry-back (House and Senate) Enhanced security for consumer data (data breaches) - responsible parties responsibility for fraud losses and the cost of mitigation, sharing of information, and a national standard for notification, community banks bearing the majority of fraud losses and reissuance costs, retailers responsibility to protect sensitive customer data (House and Senate) Expanded powers for tax-exempt credit unions - outdated original business model and straying from founding purpose, federal tax-exemption status, expansion of powers, level the playing field between community banks and credit unions, regulatory requirements including the Community Reinvestment Act (CRA) Including, expanded lending powers by increasing percentage of asset cap on business lending, and raising capital from outside investors (House and Senate) Expansion of the Farm Credit System - funding & tax advantages, expansionist agenda, competitive advantages over rural community banks, regulatory safeguards and controls, Co-Banks $725 million participation in commitment to Verizon Communications (House and Senate) Mortgage lending reforms - imprudent lending practices, impacting responsible lenders and loan products, meeting the diverse needs of community bank customers and their communities, differences between non-traditional versus predatory lending practices, exemption of community bank mortgage loans held in portfolio, restrictions on balloon mortgages and escrow requirements, prepayment penalties, originator compensation, limited credit availability Including, Qualified Mortgage (QM) status from the CFPBs Ability-to-Repay rules for loans originated and held in portfolio by community banks, balloon mortgages regardless of pricing, use of rural and underserved designations for QM eligibility for community banks and greatly expanding the definition of each, annual loan origination and asset threshold limits for small creditors, small servicer exemption for loans held in portfolio, community banks exemption from escrow requirements for loans held in portfolio and for small dollar amount loans, proposed adoption of the QM definition for Qualified Residential Mortgages (QRM) that would not require a high down-payment requirement (House and Senate)Housing Finance (GSE Secondary Market) Reform - Fannie Mae/Freddie Mac/FHFA unsustainable long-term conservatorship, community bank access to an impartial secondary market for residential mortgage loans, financial stable and reliable, government tie to secondary market (continued flow of credit and market liquidity), aggressive repurchase requests of transferred residential mortgages for technical violations Including, selling loans through an independent entity that does not compete with community banks, no appropriation of community bank customer data for the purpose of cross selling financial services, the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market, pricing of any governmental guaranties, fairness and equality to all participants regardless of volume of loans guaranteed, and further consolidation of housing finance system that would result in several mega banks and financial firms dominating the market (House and Senate) Tax, accounting and auditing changes - community bank focus supporting robust economic activity, savings & investments, accommodation/exemption for community banks, undue regulatory burden or cost on community banks Including, tax reform that preserves the pass-through option, including the Subchapter S corporation and the ability of business borrowers to deduct interest, taxation of capital gains and dividends held in parity and at a preferential rate, tax-exempt status of interest paid on municipal bonds together with an increase in the Bank Qualified (BQ) annual threshold to $30 million and indexed for inflation, the ability of business and mortgage borrowers to deduct interest without further limitations must also be preserved, changes to the tax laws that disadvantage one form of corporate entity versus another should include a phase-in period and an amnesty to allow for a penalty-free corporate conversion, S corporation banks ability to raise capital to be enhanced by giving them the ability to issue preferred stock, increasing their shareholder limits and allowing new IRA shareholder investments, end to the tax subsidies for credit unions and the FCS lenders, community banks amortizing CRE losses over 10 years (versus in the year in which they are taken), capital standards that recognize the loss-absorbing abilities of the entire amount of the Allowance for Loan and Lease Losses (ALLL), the 1.25% ALLL disallowance (for regulatory capital purposes) should be eliminated which would encourage banks to reserve more and would strengthen capital positions, the work of the Financial Accounting Foundations Private Company Council to seek recognition, measurement and disclosure alternatives for small private companies including non-public community banks. Including, Financial Accounting Standard Boards (FASB) proposed expected loss model requiring community banks to develop costly complex cash flow models for loans and investment securities to generate expected losses over the lives of these assets where implementing this proposal will be to frontload loss recognition which would harm both community bank earnings and capital, FASBs proposal to restrict the ability of community banks to classify mortgage loans and investment securities at amortized cost when their intent is to collect contractual cash flows which is based on the exit price of a loan or security and on the current value in a non-distressed market and which would require costly robust pricing engines and complex valuation methodologies to satisfy the standard, FASBs proposal to require extensive liquidity risk and interest rate risk footnote disclosures that would be required to be audited which would undermine the work of the prudential regulators whose job entails assessing the safety and soundness of community banks including an assessment of liquidity and interest rate risk, and new bank specific fees or punitive tax levies specifically targeting the financial service sector (House and Senate) Remaining Implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act Including, rein in Significantly Important Financial Institution (SIFI) with enhanced prudential standards and rigorous focused regulation, higher capital requirements, capital surcharges, concentration limits, liquidity requirements, orderly liquidation rules, credible contingency resolution plan, shielding community banks from the Dodd-Frank required increase in the deposit insurance fund reserve ratio from 1.15% to 1.35%, Volcker Rules prohibition on propriety trading and investment in and sponsorship of hedge funds and private equity funds, effectively exempting community banks Including, ensure the Consumer Financial Protection Bureau (CFPB) focuses on large banks, financial firms and shadow financial companies, holding the mega banks and financial firms up to the same high standards for compliance with consumer laws as required and attained by community banks, governance (single Director versus five member commission), prudential regulators participation with CFPB in the rule writing process, FSOC veto of CFPB rules, CFPB exemption authority regardingcommunity banks, revision in the definitions of rural and underserved areas in the Ability to Repays Qualified Mortgage (QM) rules, consistent and transparent standards in the evaluation of community bank fair lending standards, disparate impact and unintentional discrimination (House and Senate) De novo community bank formation - need to maintain growing, vibrant & evolving banking profession, Federal Deposit Insurance Corporations (FDIC) actively inhibiting de novo community bank formation, inappropriate and restrictive one-size-fits-all supervisory policy (House and Senate) Maintain the Federal Home Loan Bank (FHLB)System - strong partnership with community banks, healthy, stable & reliable source of funding for community banks, FHLBs should not be the sole aggregators for residential mortgages for community banks in the reform of the housing GSEs, preservation of the FHLBs special functions and purposes (House and Senate) Excessive (Federal Reserve) intervention in monetary policy - significant drag on community banks net interest margins and earnings, limits on what monetary policy can accomplish, impact on community banks, savers and senior citizens (House and Senate) ***** S. 798 Terminating Bailouts for Taxpayers Fairness Act of 2013 (capital requirements, Basel III, and community bank regulatory relief) (all sections) (Senate) S. 635 Privacy Act Notice Modernization Act of 2013 (redundant privacy notice regulatory relief) (all sections) (Senate) H.R. 1750 CLEAR Relief Act of 2013 (community lending enhancement and regulatory relief) (all sections) (House) CBAI Comment Letters - Comment Letter CFPB Advanced Notice of Proposed Rulemaking, Debt Collection (Regulation F), Docket No. CFPB-2013-0033-0001, RIN 3170-AA41 Comment Letter FHFA Fannie Mae and Freddie Mac Loan Purchase Limits: Request for Public Input on Implementation Issues No. 2013-N-18 Comment Letter Federal Reserve Bank of Chicago, Federal Deposit Insurance Corporation (Chicago Regional Office), and Illinois Department of financial and Professional Regulation (IDFPR) Regarding TruPS and Consent Order Dividend Restrictions CBAI Action Alerts H.R. 4521 Community Institution Mortgage Relief Act (exempt community bank portfolio loans from new escrow requirements and raise the small services exemption) (all sections) (House) H.R. 4466 Financial Regulatory Clarity Act (requires federal regulators to consider whether proposed regulations are duplicative or inconsistent with existing regulations) (all sections) (House) H.R. 2673 Portfolio Lending and Mortgage Access Act (any residential mortgage held in portfolio by the originator is a Qualified Mortgage) (all sections) (House)

Credit unions' tax exemption and expansion of powers, level the playing field between community banks and credit unions (House and Senate) H.R. 688 - Credit Union Small Business Job Creation Act (credit union member business lending cap) (all sections) (House and Senate)S. 968 Small Business Lending Enhancement Act of 2013 (credit union member business lending cap) (all sections) (House and Senate) H.R. 719 Capital Access for Small Business and Jobs Act (credit union capital) (all sections) (House and Senate) Expansion of the Farm Credit Administrations Farm Credit System (House and Senate) CoBank participation in a loan to Verizon Communications. (House and Senate) Municipal Bond tax exemptions, Bank Qualified (BQ) small issuer exemption threshold/index for inflation (House and Senate)

S. 798 - Terminating Bailouts for Taxpayers Fairness Act of 2013 (capital requirements, Basel III, and community bank regulatory relief) (all sections) (House and Senate) H.R. 1750 - CLEAR Act (community lending enhancement and regulatory relief) (all sections) (House and Senate) S. 1349 - CLEAR Act (community lending enhancement and regulatory relief) (all sections) (House and Senate)S. 635 Privacy Notice Modernization Act (redundant privacy notices) (all sections) (House and Senate) H.R. 1553 Financial Institution Examination Fairness and Reform Act (amends FFIEC Act, examination standards/deadlines, FFIEC Office of Examination Ombudsman to appeal examination findings, right to appeal before independent administrative law judge ) (all sections) (House and Senate) S. 727 Financial Institution Fairness Reform Act (amends FFIEC Act, examination standards/deadlines, FFIEC Office of Examination Ombudsman to appeal examination findings, right to appeal before independent administrative law judge ) (all sections) (House and Senate) S. 872 Holding Company Registration Act (thrift holding companies and SEC registration and deregistration thresholds) (all sections) (House and Senate) H.R. 797 Municipal Advisory Oversight improvement Act (exempts traditional banking activities from registration requirements) (all sections) (House and Senate) S. 710 Municipal Advisor Relief Act of 2013 (exempts traditional banking activities from registration requirements) (all sections) (House and Senate) Credit unions tax exemption and expansion of powers, level the playing field between community banks and credit unions (House and Senate) H.R. 688 Credit Union Small Business Job Creation Act (credit union member business lending cap) (all sections) (House and Senate) S. 968 Small Business Lending Enhancement Act of 2013 (credit union member business lending cap) (all sections) (House and Senate) H.R. 719 Capital Access for Small Business and Jobs Act (credit union capital) (all sections) (House and Senate) Consumer Data Security (data breaches), banking standards for confidential personal information, allocating financial responsibility for fraud losses and reissuance costs, single national standard for consumer notifications (House and Senate) Definitions of rural and underserved areas in the Ability to Repay Qualified Mortgage (QM) Rules (House and Senate) Comment letter Federal Housing Finance Agency - Fannie Mae and Freddie Mac Loan Purchase Limits: Request for Public Input on Implementation Issues No. 2013-N-18 (FHFA conforming loan limits for the Chicago Metropolitan Statistical Area (MSA)) (House and Senate, FHFA) Expansion of the Farm Credit Administrations Farm Credit System (House and Senate) CoBank participation in a loan to Verizon Communications. (House and Senate) Municipal Bond tax exemption, Bank Qualified (BQ) small issuer exemption threshold/index for inflation (House and Senate) Principals of housing finance reform including: equal and direct access on a loan by loan basis, financial strength and reliability and liquidity, loan pricing on equal terms, no appropriation of customer information, originators option to retain servicing, limited purpose and activity, private capital to protect taxpayers, FHLBs as an access point for community banks, consolidation of the housing finance system (House and Senate) H.R. 2642 - Agricultural Act of 2014 (five year farm bill, expanded crop insurance and revenue- and price-triggered supports) (Senate)Community bank experience on the Federal Reserve Board (Senate) Fair Lending disparate impact (House) Comment Letter Consumer Financial Protection Bureau Advanced Notice of Proposed Rulemaking, Debt Collection (Regulation F), Docket No. CFPB-2013-0033-0001, RIN 3170-AA41 (new debt collection rules) (CFPB) Comment Letter Consumer Financial Protection Bureau, Federal Reserve Board, Office of Comptroller of the Currency, Federal Deposit Insurance Corporation, National Credit Union Administration, Securities and Exchange Commission Proposed Interagency Policy Statement Establishing Joint Standards for Assessing the Diversity Policies and Practices of Entities Regulated by the Agencies (Dodd-Frank diversity regulations) (CFPB, Fed Reserve Board, OCC, FDIC, NCUA, SEC)

S. 798 - Terminating Bailouts for Taxpayers Fairness Act of 2013 (capital requirements, Basel III, and community bank regulatory relief) (all sections) (House and Senate) H.R. 1750 - CLEAR Act (community lending enhancement and regulatory relief) (all sections) (House and Senate) S. 1349 - CLEAR Act (community lending enhancement and regulatory relief) (all sections) (House and Senate)S. 635 Privacy Notice Modernization Act (redundant privacy notices) (all sections) (House and Senate) H.R. 1553 Financial Institution Examination Fairness and Reform Act (amends FFIEC Act, examination standards/deadlines, FFIEC Office of Examination Ombudsman to appeal examination findings, right to appeal before independent administrative law judge ) (all sections) (House and Senate) S. 727 Financial Institution Fairness Reform Act (amends FFIEC Act, examination standards/deadlines, FFIEC Office of Examination Ombudsman to appeal examination findings, right to appeal before independent administrative law judge ) (all sections) (House and Senate) S. 872 Holding Company Registration Act (thrift holding companies and SEC registration and deregistration thresholds) (all sections) (House and Senate) H.R. 797 Municipal Advisory Oversight improvement Act (exempts traditional banking activities from registration requirements) (all sections) (House and Senate) S. 710 Municipal Advisor Relief Act of 2013 (exempts traditional banking activities from registration requirements) (all sections) (House and Senate) Credit unions tax exemption and expansion of powers, level the playing field between community banks and credit unions (House and Senate) H.R. 688 Credit Union Small Business Job Creation Act (credit union member business lending cap) (all sections) (House and Senate) S. 968 Small Business Lending Enhancement Act of 2013 (credit union member business lending cap) (all sections) (House and Senate) H.R. 719 Capital Access for Small Business and Jobs Act (credit union capital) (all sections) (House and Senate) Consumer Data Security (data breaches), banking standards for confidential personal information, allocating financial responsibility for fraud losses and reissuance costs, single national standard for consumer notifications (House and Senate) Definitions of rural and underserved areas in the Ability to Repay Qualified Mortgage (QM) Rules (House and Senate) Comment letter Federal Housing Finance Agency - Fannie Mae and Freddie Mac Loan Purchase Limits: Request for Public Input on Implementation Issues No. 2013-N-18 (FHFA conforming loan limits for the Chicago Metropolitan Statistical Area (MSA)) (House and Senate, FHFA) Expansion of the Farm Credit Administrations Farm Credit System (House and Senate) CoBank participation in a loan to Verizon Communications. (House and Senate) Municipal Bond tax exemption, Bank Qualified (BQ) small issuer exemption threshold/index for inflation (House and Senate) Principals of housing finance reform including: equal and direct access on a loan by loan basis, financial strength and reliability and liquidity, loan pricing on equal terms, no appropriation of customer information, originators option to retain servicing, limited purpose and activity, private capital to protect taxpayers, FHLBs as an access point for community banks, consolidation of the housing finance system (House and Senate) H.R. 2642 - Agricultural Act of 2014 (five year farm bill, expanded crop insurance and revenue- and price-triggered supports) (Senate)Community bank experience on the Federal Reserve Board (Senate) Fair Lending disparate impact (House) Comment Letter Consumer Financial Protection Bureau Advanced Notice of Proposed Rulemaking, Debt Collection (Regulation F), Docket No. CFPB-2013-0033-0001, RIN 3170-AA41 (new debt collection rules) (CFPB) Comment Letter Consumer Financial Protection Bureau, Federal Reserve Board, Office of Comptroller of the Currency, Federal Deposit Insurance Corporation, National Credit Union Administration, Securities and Exchange Commission Proposed Interagency Policy Statement Establishing Joint Standards for Assessing the Diversity Policies and Practices of Entities Regulated by the Agencies (Dodd-Frank diversity regulations) (CFPB, Fed Reserve Board, OCC, FDIC, NCUA, SEC)

Mortgage lending reforms imprudent lending practices, impacting responsible lenders and loan products, meeting the diverse needs of community bank customers and their communities, exemption of community bank mortgage loans held in portfolio, restrictions on balloon mortgages and escrow requirements, broad definition of Qualified Mortgage (QM), limited credit availability (Federal Reserve)Housing Finance GSE secondary market reform community bank access to an impartial secondary market for residential loans, financial stable and reliable, private capitalization, cooperative entities with limited mission (Federal Reserve) Principals of housing finance reform including: equal and direct access on a loan by loan basis, financial strength and reliability and liquidity, no appropriation of customer information, originators option to retain servicing, limited purpose and activity, private capital to protect taxpayers, restoration of Fannie and Freddie preferred share value (FHFA) S. 635 Privacy Notice Modernization Act (exemption regarding privacy notices) (all Sections) (House and Senate, CFPB, OCC) H.R. 749 Eliminate Privacy Notification Confusion Act (annual privacy notices) (all sections) (House and Senate, CFPB, OCC) Implementation date for the Ability to Repay Qualified Mortgage (QM) Rules (CFPB) Definitions of rural and underserved areas in the Ability to Repay Qualified Mortgage (QM) Rules (House and Senate, CFPB) FHFA conforming loan limits for the Chicago Metropolitan Statistical Area (MSA) (House and FHFA)

Expansion of the Farm Credit System, Rural Community Investments proposal, wholesale funding for community banks, correspondent services, and direct retail competition with community banks (Federal Reserve, House and Senate, CFPB, OCC) CoBank participation in a loan to Verizon Communications. (House and Senate)

Credit unions tax exemption and expansion of powers, level the playing field between community banks and credit unions (Federal Reserve, House and Senate, CFPB, OCC) Tax, accounting and auditing changes pass-through option, including subchapter S corporations, taxation of capital gains and dividends, interest on municipal bonds, S corporation ability to issue preferred stock, shareholder limits, and allowing new IRAshareholders, amortizing CRE losses over 10 years, elimination of the 1.25% Allowance for Loan and Lease losses disallowance for regulatory capital purposes (Federal Reserve) H.R. 688 Credit Union Small Business Job Creation Act (credit union member business lending cap) (all sections) (House and Senate, CFPB, OCC) S. 968 Small Business Lending Enhancement Act of 2013 (credit union member business lending cap) (all sections) (House and Senate, CFPB, OCC) H.R. 719 Capital Access for Small Business and Jobs Act (credit union capital) (all sections) (House and Senate, CFPB, OCC) Expansion of the Farm Credit System, Rural Community Investments proposal, wholesale funding for community banks, correspondent services, and direct retail competition with community banks (Federal Reserve, House and Senate, CFPB, OCC) CoBank participation in a loan to Verizon Communications. (House and Senate)

Reform of the financial system, downsizing too-big-to-fail banks and financial firms, reduce the probability and severity of future financial crisis, too-big-to-manage, too-big-to-regulate, too-big-to-fail, too-big-to-prosecute, and too-big-to-jail (Federal Reserve) Community bank regulatory relief contained in the Independent Community Bankers of America (ICBA's) Plan for Prosperity (Federal Reserve)Tiered regulation and supervision for community banks, recognition of the different business model and risks posed by community banks versus too-big-to-fail banks and financial firms, one size fits all legislation and regulation (Federal Reserve) Application of Basel III to community banks, exemption from the capital and risk-weight requirements of Basel III (Federal Reserve) Credit unions tax exemption and expansion of powers, level the playing field between community banks and credit unions (Federal Reserve) Expansion of the Farm Credit System, Rural Community Investments proposal, wholesale funding for community banks, correspondent services, and direct retail competition with community banks (Federal Reserve) Mortgage lending reforms imprudent lending practices, impacting responsible lenders and loan products, meeting the diverse needs of community bank customers and their communities, exemption of community bank mortgage loans held in portfolio, restrictions on balloon mortgages and escrow requirements, broad definition of Qualified Mortgage (QM), limited credit availability (Federal Reserve) Housing Finance GSE secondary market reform community bank access to an impartial secondary market for residential loans, financial stable and reliable, private capitalization, cooperative entities with limited mission (Federal Reserve) Aggressive bank regulatory examinations regulator, senior management, and examiner attitudes and practices, treatment of Commercial Real Estate, excessive write-downs, arbitrary capital requirements, public enforcement actions, reform the appellate process, and community bank closures (Federal Reserve) Tax, accounting and auditing changes pass-through option, including subchapter S corporations, taxation of capital gains and dividends, interest on municipal bonds, S corporation ability to issue preferred stock, shareholder limits, and allowing new IRA shareholders, amortizing CRE losses over 10 years, elimination of the 1.25% Allowance for Loan and Lease losses disallowance for regulatory capital purposes (Federal Reserve) Continuing implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act - Rein in Significantly Important Financial institution (SIFI) with focused regulation including resolution plans, higher capital requirements, capital surcharges, liquidity requirements, the Volker Rule, level playing field between community banks and SIFIs, shielding community banks from the Dodd-Frank required increase in the deposit insurance fund reserve ratio from 1.15% to 1.35%, focus CFPB on large banks and shadow financial companies, governance (single Director versus five member commission), FSOC veto of CFPB rules, CFPB exemption authority regarding community banks (Federal Reserve) Maintain the Federal Home Loan Bank System and preserve their special functions and purposes (Federal Reserve) Permanent closing of the ILC loophole (Federal Reserve) Fairly compensate Fannie and Freddie preferred shareholders by restoring the share value and dividends (Federal Reserve) Excessive Federal Reserve intervention in monetary policy (Federal Reserve) S. 798 Terminating Bailouts for Taxpayers Fairness Act of 2013 (capital requirements, Basel III, and community bank regulatory relief) (all sections) (House and Senate, CFPB, OCC) Credit unions tax exemption and expansion of powers, level the playing field between community banks and credit unions (House and Senate, CFPB, OCC) H.R. 688 Credit Union Small Business Job Creation Act (credit union member business lending cap) (all sections) (House and Senate, CFPB, OCC)S. 968 Small Business Lending Enhancement Act of 2013 (credit union member business lending cap) (all sections) (House and Senate, CFPB, OCC) H.R. 719 Capital Access for Small Business and Jobs Act (credit union capital) (all sections) (House and Senate, CFPB, OCC) Expansion of the Farm Credit System, Rural Community Investments proposal, wholesale funding for community banks, correspondent services, direct retail competition with community banks (House and Senate, CFPB, OCC) CoBank participation in a loan to Verizon Communications. (House and Senate) S. 635 Privacy Notice Modernization Act (exemption regarding privacy notices) (all Sections) (House and Senate, CFPB, OCC) S. 710 Municipal Advisor Relief Act of 2013 (exemption for the identity of municipal advisor) (all sections) (House and Senate, CFPB, OCC) S. 727 Financial Institution Fairness Reform Act (create ombudsman within FFIEC to appeal examination findings, right to appeal before independent administrative law judge) (House and Senate, CFPB, OCC) H.R. 1750 CLEAR Act (community lending enhancement and regulatory relief) (all sections) (House and Senate, CFPB, OCC) S. 1349 CLEAR Act (community lending enhancement and regulatory relief) (all sections) (House and Senate, CFPB, OCC) Principals of housing finance reform including: equal and direct access on a loan by loan basis, financial strength and reliability and liquidity, no appropriation of customer information, originators option to retain servicing, limited purpose and activity, private capital to protect taxpayers, restoration of Fannie and Freddie preferred share value (FHFA) FHFA conforming loan limits for the Chicago Metropolitan Statistical Area (MSA) (House and FHFA) H.R. 749 Eliminate Privacy Notification Confusion Act (annual privacy notices) (all sections) (House and Senate, CFPB, OCC) H.R. 1553 Financial Institution Examination Fairness and Reform Act (amends FFIEC Act, examination standards/deadlines, FFIEC Office of Examination Ombudsman) (all sections) (House and Senate, CFPB, OCC) Financial Accounting Standards Boards (FASB) Incurred Loss versus Expected Loss method of determining the sufficiency of the Allowance for Loan and Lease Losses (FASB) H.R. 3309 Innovation Act (patent trolls) (all sections) (House) Implementation date for the Ability to Repay Qualified Mortgage (QM) Rules (CFPB) Definitions of rural and underserved areas in the Ability to Repay Qualified Mortgage (QM) Rules (House and Senate, CFPB) Trust Preferred Securities (TruPS) treatment in the Volcker Rule (House and Senate)

Mortgage lending reforms imprudent lending practices, impacting responsible lenders and loan products, meeting the diverse needs of community bank customers and their communities, exemption of community bank mortgage loans held in portfolio, restrictions on balloon mortgages and escrow requirements, broad definition of Qualified Mortgage (QM), limited credit availability (House and Senate)Housing Finance GSE secondary market reform community bank access to an impartial secondary market for residential loans, financial stable and reliable, private capitalization, cooperative entities with limited mission (House and Senate) Principals of housing finance reform including: equal and direct access on a loan by loan basis, financial strength and reliability and liquidity, no appropriation of customer information, originators option to retain servicing, limited purpose and activity, private capital to protect taxpayers, restoration of Fannie and Freddie preferred share value (House and FHFA) S. 635 Privacy Notice Modernization Act (exemption regarding privacy notices) (all Sections) (House and Senate, CFPB, OCC)

Reform of the financial system, downsizing too-big-to-fail banks and financial firms, reduce the probability and severity of future financial crisis, too-big-to-manage, too-big-to-regulate, too-big-to-fail, too-big-to-prosecute, and too-big-to-jail (House and Senate) Community bank regulatory relief contained in the Independent Community Bankers of America (ICBA's) Plan for Prosperity (House and Senate)Tiered regulation and supervision for community banks, recognition of the different business model and risks posed by community banks versus too-big-to-fail banks and financial firms, one size fits all legislation and regulation (House and Senate, CFPB, OCC) Application of Basel III to community banks, exemption from the capital and risk-weight requirements of Basel III (House and Senate) Credit unions tax exemption and expansion of powers, level the playing field between community banks and credit unions (House and Senate) Expansion of the Farm Credit System, Rural Community Investments proposal, wholesale funding for community banks, correspondent services, direct retail competition with community banks (House and Senate, CFPB, OCC) Mortgage lending reforms imprudent lending practices, impacting responsible lenders and loan products, meeting the diverse needs of community bank customers and their communities, exemption of community bank mortgage loans held in portfolio, restrictions on balloon mortgages and escrow requirements, broad definition of Qualified Mortgage (QM), limited credit availability (House and Senate) Housing Finance GSE secondary market reform community bank access to an impartial secondary market for residential loans, financial stable and reliable, private capitalization, cooperative entities with limited mission (House and Senate) Aggressive bank regulatory examinations regulator, senior management, and examiner attitudes and practices, treatment of Commercial Real Estate, excessive write-downs, arbitrary capital requirements, public enforcement actions, reform the appellate process, and community bank closures (House and Senate) Tax, accounting and auditing changes pass-through option, including subchapter S corporations, taxation of capital gains and dividends, interest on municipal bonds, S corporation ability to issue preferred stock, shareholder limits, and allowing new IRA shareholders, amortizing CRE losses over 10 years, elimination of the 1.25% Allowance for Loan and Lease losses disallowance for regulatory capital purposes (House and Senate) Continuing implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act - Rein in Significantly Important Financial institution (SIFI) with focused regulation including resolution plans, higher capital requirements, capital surcharges, liquidity requirements, the Volker Rule, level playing field between community banks and SIFIs, shielding community banks from the Dodd-Frank required increase in the deposit insurance fund reserve ratio from 1.15% to 1.35%, focus CFPB on large banks and shadow financial companies, governance (single Director versus five member commission), FSOC veto of CFPB rules, CFPB exemption authority regarding community banks (House and Senate) Maintain the Federal Home Loan Bank System and preserve their special functions and purposes (House and Senate) Permanent closing of the ILC loophole (House and Senate) Fairly compensate Fannie and Freddie preferred shareholders by restoring the share value and dividends (House and Senate) Excessive Federal Reserve intervention in monetary policy (House and Senate) S. 798 Terminating Bailouts for Taxpayers Fairness Act of 2013 (capital requirements, Basel III, and community bank regulatory relief) (all sections) (House and Senate, CFPB, OCC) S. 635 Privacy Notice Modernization Act (exemption regarding privacy notices) (all Sections) (House and Senate, CFPB, OCC) S. 710 Municipal Advisor Relief Act of 2013 (exemption for the identity of municipal advisor) (all sections) (Senate)S. 872 Holding Company Registration Equalization Act (thrift holding company deregistration threshold) (all sections) (Senate) S. 727 Financial Institution Fairness Reform Act (create ombudsman within FFIEC to appeal examination findings, right to appeal before independent administrative law judge) (Senate) Principals of housing finance reform including: equal and direct access on a loan by loan basis, financial strength and reliability and liquidity, no appropriation of customer information, originators option to retain servicing, limited purpose and activity, private capital to protect taxpayers, restoration of Fannie and Freddie preferred share value (House and FHFA) H.R. 1750 CLEAR Relief Act of 2013 (community lending enhancement and regulatory relief) (all sections) (House and Senate, CFPB, OCC) H.R. 688 Credit Union Small Business Job Creation Act (credit union member business lending cap) (all sections) (House and Senate, CFPB, OCC) S. 968 Small Business Lending Enhancement Act of 2013 (credit union member business lending cap) (all sections) (House and Senate, CFPB, OCC) H.R. 719 Capital Access for Small Business and Jobs Act (credit union capital) (all sections) (House and Senate, CFPB, OCC)

Expansion of the Farm Credit System, Rural Community Investments proposal, wholesale funding for community banks, correspondent services, direct retail competition with community banks (House and Senate, CFPB, OCC)

Reform of the financial system, downsizing too-big-to-fail banks and financial firms, reduce the probability and severity of future financial crisis, too-big-to-manage, too-big-to-regulate, too-big-to-fail, too-big-to-prosecute, and too-big-to-jail (House and Senate)Community bank regulatory relief contained in the Independent Community Bankers of America Plan for Prosperity (House and Senate) Tiered regulation and supervision for community banks, recognition of the different business model and risks posed by community banks versus too-big-to-fail banks and financial firms, one size fits all legislation and regulation (House and Senate) Application of Basel III to community banks, exemption from the capital and risk-weight requirements of Basel III (House and Senate) Credit unions tax exemption and expansion of powers, level the playing field between community banks and credit unions (House and Senate) Expansion of the Farm Credit System, Rural Community Investments proposal, wholesale funding for community banks, correspondent services, direct retail competition with community banks (House and Senate) Mortgage lending reforms imprudent lending practices, impacting responsible lenders and loan products, meeting the diverse needs of community bank customers and their communities, exemption of community bank mortgage loans held in portfolio, restrictions on balloon mortgages and escrow requirements, broad definition of Qualified Mortgage (QM), limited credit availability (House and Senate) Housing GSE reform community bank access to an impartial secondary market for residential loans, financial stable and reliable, private capitalization, cooperative entities with limited mission (House and Senate) Aggressive bank regulatory examinations regulator, senior management, and examiner attitudes and practices, treatment of Commercial Real Estate, excessive write-downs, arbitrary capital requirements, public enforcement actions, reform the appellate process, and community bank closures (House and Senate) Tax, accounting and auditing changes pass-through option, including subchapter S corporations, taxation of capital gains and dividends, interest on municipal bonds, S corporation ability to issue preferred stock, shareholder limits, and allowing new IRA shareholders, amortizing CRE losses over 10 years, elimination of the 1.25% Allowance for Loan and Lease losses disallowance for regulatory capital purposes (House and Senate) Continuing implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act - Rein in Significantly Important Financial institution (SIFI) with focused regulation including resolution plans, higher capital requirements, capital surcharges, liquidity requirements, the Volker Rule, level playing field between community banks and SIFIs, shielding community banks from the Dodd-Frank required increase in the deposit insurance fund reserve ratio from 1.15% to 1.35%, focus CFPB on large banks and shadow financial companies, governance (single Director versus five member commission), FSOC veto of CFPB rules, CFPB exemption authority regarding community banks (House and Senate) Maintain the Federal Home Loan Bank System and preserve their special functions and purposes (House and Senate) Permanent closing of the ILC loophole (House and Senate) Fairly compensate Fannie and Freddie preferred shareholders by restoring the share value and dividends (House and Senate) Excessive Federal Reserve intervention in monetary policy (House and Senate) S. 798 Terminating Bailouts for Taxpayers Fairness Act of 2013 (capital requirements, Basel III, and community bank regulatory relief) (all sections) (Senate) H.R. 749 Eliminate Privacy Notice Confusion Act (exemption regarding privacy notices) (all sections) (House and Senate)H.R. 797 Municipal Advisor Oversight Improvement Act of 2013 (Amends the SEC Act of 1934 regarding non-registered municipal advisors) (all sections) (House and Senate) S. 710 Municipal Advisor Relief Act of 2013 (exemption for the identity of municipal advisor) (all sections) (House and Senate) S. 205 Responsible Consumer Financial Protection Regulation Act of 2013 (Amends Title X of the Dodd-Frank regarding CFPB) (all sections) (House and Senate) H.R. 801 Holding Company Registration Threshold Equalization Act of 2013 (Amends the SEC Act of 1934 regarding savings and loan holding company registration) (all sections) (House and Senate) H.R. 1062 SEC Regulatory Accountability Act (Amends the SEC Act of 1934 regarding justification of new rules) (all sections) (House and Senate) S. 450 Financial Regulatory Responsibility Act of 2013 (justification of new rules) (all sections) (House and Senate) H.R. 1750 CLEAR Relief Act of 2013 (community lending enhancement and regulatory relief) (all sections) (House ) H.R. 688 Credit Union Small Business Job Creation Act (credit union member business lending cap) (all sections) (House and Senate) H.R. 719 Capital Access for Small Business and Jobs Act (credit union capital) (all sections) (House and Senate)

Reform of the financial system, downsizing too-big-to-fail banks and financial firms, reduce the probability and severity of future financial crisis, too-big-to-manage, too-big-to-regulate, too-big-to-fail, too-big-to-prosecute, and too-big-to-jail (House and Senate)Community bank regulatory relief contained in the Independent Community Bankers of America Plan for Prosperity (House and Senate) Tiered regulation and supervision for community banks, recognition of the different business model and risks posed by community banks versus too-big-to-fail banks and financial firms, one size fits all legislation and regulation (House and Senate) Application of Basel III to community banks, exemption from the capital and risk-weight requirements of Basel III (House and Senate) Credit unions tax exemption and expansion of powers, level the playing field between community banks and credit unions (House and Senate) Expansion of the Farm Credit System, Rural Community Investments proposal, wholesale funding for community banks, correspondent services, direct retail competition with community banks (House and Senate) Mortgage lending reforms imprudent lending practices, impacting responsible lenders and loan products, meeting the diverse needs of community bank customers and their communities, exemption of community bank mortgage loans held in portfolio, restrictions on balloon mortgages and escrow requirements, broad definition of Qualified Mortgage (QM), limited credit availability (House and Senate) Housing GSE reform community bank access to an impartial secondary market for residential loans, financial stable and reliable, private capitalization, cooperative entities with limited mission (House and Senate) Aggressive bank regulatory examinations regulator, senior management, and examiner attitudes and practices, treatment of Commercial Real Estate, excessive write-downs, arbitrary capital requirements, public enforcement actions, reform the appellate process, and community bank closures (House and Senate) Tax, accounting and auditing changes pass-through option, including subchapter S corporations, taxation of capital gains and dividends, interest on municipal bonds, S corporation ability to issue preferred stock, shareholder limits, and allowing new IRA shareholders, amortizing CRE losses over 10 years, elimination of the 1.25% Allowance for Loan and Lease losses disallowance for regulatory capital purposes (House and Senate) Continuing implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act - Rein in Significantly Important Financial institution (SIFI) with focused regulation including resolution plans, higher capital requirements, capital surcharges, liquidity requirements, the Volker Rule, level playing field between community banks and SIFIs, shielding community banks from the Dodd-Frank required increase in the deposit insurance fund reserve ratio from 1.15% to 1.35%, focus CFPB on large banks and shadow financial companies, governance (single Director versus five member commission), FSOC veto of CFPB rules, CFPB exemption authority regarding community banks (House and Senate) Maintain the Federal Home Loan Bank System and preserve their special functions and purposes (House and Senate) Permanent closing of the ILC loophole (House and Senate) Fairly compensate Fannie and Freddie preferred shareholders by restoring the share value and dividends (House and Senate) Excessive Federal Reserve intervention in monetary policy (House and Senate) S. 798 Terminating Bailouts for Taxpayers Fairness Act of 2013 (capital requirements, Basel III, and community bank regulatory relief) (all sections) (Senate) H.R. 749 Eliminate Privacy Notice Confusion Act (exemption regarding privacy notices) (all sections) (House and Senate)H.R. 797 Municipal Advisor Oversight Improvement Act of 2013 (Amends the SEC Act of 1934 regarding non-registered municipal advisors) (all sections) (House and Senate) S. 710 Municipal Advisor Relief Act of 2013 (exemption for the identity of municipal advisor) (all sections) (House and Senate) S. 205 Responsible Consumer Financial Protection Regulation Act of 2013 (Amends Title X of the Dodd-Frank regarding CFPB) (all sections) (House and Senate) H.R. 801 Holding Company Registration Threshold Equalization Act of 2013 (Amends the SEC Act of 1934 regarding savings and loan holding company registration) (all sections) (House and Senate) H.R. 1062 SEC Regulatory Accountability Act (Amends the SEC Act of 1934 regarding justification of new rules) (all sections) (House and Senate) S. 450 Financial Regulatory Responsibility Act of 2013 (justification of new rules) (all sections) (House and Senate) H.R. 1750 CLEAR Relief Act of 2013 (community lending enhancement and regulatory relief) (all sections) (House) H.R. 688 Credit Union Small Business Job Creation Act (credit union member business lending cap) (all sections) (House and Senate) H.R. 719 Capital Access for Small Business and Jobs Act (credit union capital) (all sections) (House and Senate)

Downsizing too-big-to-fail banks and financial firms (House and Senate) Too-big-to-fail banks and financial firms which are too-big-to-prosecute and too-big-to-jail (Treasury-OCC)Community bank exemption from Basel III - Minimum Regulatory Capital and the Standardized Approach for Risk-weighted Assets (House and Senate and Treasury-OCC) Tiered regulation for community banks (House and Senate) Reform of the housing GSE without disadvantaging community banks (House and Senate) Manufacturing Reinvestment Act (112th Congress H.R. 110) (House) Results of implementation of debit interchange rule (Senate) Private credit union membership in Federal Home Loan Banks (House) H.R. 749 - Eliminate Privacy Confusion Act (annual privacy notices) (House) Loan underwriting standards intangible considerations versus documentary evidence (Treasury-OCC) De novo bank chartering activity (Treasury-OCC) Mutual charter issues including: understanding mutual charters, focus on increased profitability, imposition of certain commercial loan accounting (GAAP and FASB) standards to residential lending (Treasury-OCC) Various residential mortgage lending issues including: importance of mortgage lending, streamlining the mortgage lending process, the need for input in rulemaking, safe harbor vs. rebuttable presumption in Qualified Mortgages (QM) Ability-to-Repay Standards, balloon mortgage inclusion in QM for the purpose of the safe harbor, and reasonable QM definition (Treasury-CFPB) Comment Letter regarding Proposed Amendments to Ability-to-Repay Standards under Truth in Lending (Regulation Z) Docket No. CFPB-2013-0002, RIN 3170-AA34 (Treasury-CFPB)

Manufacturing Reinvestment Act (112th Congress - H.R. 110) (House)

H.R. 749 - Eliminate Privacy Confusion Act (annual privacy notices) (House) Comment Letter regarding Proposed Amendments to Ability-to-Repay Standards under Truth in Lending (Regulation Z) Docket No. CFPB-2013-0002, RIN 3170-AA34 (Treasury-CFPB)Various residential mortgage lending issues including: importance of mortgage lending, streamlining the mortgage lending process, the need for input in rulemaking, safe harbor vs. rebuttable presumption in Qualified Mortgages (QM) Ability-to-Repay Standards, balloon mortgage inclusion in QM for the purpose of the safe harbor, and reasonable QM definition (Treasury-CFPB) Reform of the housing GSE without disadvantaging community banks (House and Senate)

Comment Letter regarding Basel III - Proposed Rulemaking on Minimum Regulatory Capital and the Standardized Approach for Risk-weighted Assets Federal Reserve Docket No. R-1430; RIN No. 7100-AD87 and Docket No. R-1442; RIN No. 7100-AD87 FDIC RIN 3064-AD95, RIN 3064-AD96 OCC Docket ID OCC-2012-0008 and Docket ID OCC-2012-0009 (House and Senate) H.R. 1418 (and S. 509 renumbered in the Senate to S. 2231) - Small Business Lending Enhancement Act of 2011 (Expansion of credit unions member business lending powers) (all sections) (House and Senate) Five-year extension of the Transaction Account Guarantee (TAG) program (House and Senate) S. 3637 A bill to temporarily extend the Transaction Account Guaranty (TAG) program, Motion to Proceed and Budgetary Point of Order (all sections) (Senate)

H.R. 1697 (and S. 1600) - Communities First Act (Community bank regulatory and tax relief) (all sections) (House and Senate) H.R. 1418 (and S. 509 renumbered in the Senate to S. 2231) - Small Business Lending Enhancement Act of 2011 (Expansion of credit unions member business lending powers) (all sections) (House and Senate) H.R. 3993 Capital Access for Small Business and Jobs Act (Credit union access to outside capital) (all sections) (House and Senate) H.R. 3461 (and S. 2160) Financial Institutions Examination Fairness Act (To improve the examination of depository institutions) (all sections) (House and Senate) H.R. 4367 (and S. 3204) ATM fee disclosure legislation to eliminate the duplicative disclosure notices on the exterior of ATM machines (House and Senate) Five-year extension of the Transaction Account Guarantee (TAG) program (House and Senate) Interest penalties for violations of reporting requirements regarding the Small Business Lending Fund (SBLF) (House and Senate and Treasury/SBLF) Comment Letter regarding Basel III - Proposed Rulemaking on Minimum Regulatory Capital and the Standardized Approach for Risk-weighted Assets extension of comment period. Federal Reserve Docket No. R-1430; RIN No. 7100-AD87 and Docket No. R-1442; RIN No. 7100-AD87 FDIC RIN 3064-AD95, RIN 3064-AD96 OCC Docket ID OCC-2012-0008 and Docket ID OCC-2012-0009 (Federal Reserve, FDIC, and Treasury/OCC) Comment Letter regarding Basel III - Proposed Rulemaking on Minimum Regulatory Capital and the Standardized Approach for Risk-weighted Assets community bank exemption. Federal Reserve Docket No. R-1430; RIN No. 7100-AD87 and Docket No. R-1442; RIN No. 7100-AD87 FDIC RIN 3064-AD95, RIN 3064-AD96 OCC Docket ID OCC-2012-0008 and Docket ID OCC-2012-0009 (Federal Reserve, FDIC, Treasury/OCC, House and Senate) Comment Letter regarding Basel III - Proposed Rulemaking on Minimum Regulatory Capital and the Standardized Approach for Risk-weighted Assets elimination of certain provisions and community bank exemption. Federal Reserve Docket No. R-1430; RIN No. 7100-AD87 and Docket No. R-1442; RIN No. 7100-AD87 FDIC RIN 3064-AD95, RIN 3064-AD96 OCC Docket ID OCC-2012-0008 and Docket ID OCC-2012-0009 (Federal Reserve, FDIC, Treasury/OCC, House and Senate) Informed House regarding the Consumer Financial Protection Bureau regarding regulatory burden, supervision of non-bank financial service providers, challenges in obtaining credit, tiered regulation, and Small Business Review Panels (House) Informed the Consumer Financial Protection Bureau regarding applicability of rules, positive feedback, consumer responsibility, focus on the largest financial institutions and the shadow financial industry, five year extension of the TAG program, and a Basel III exemption for community banks. (Treasury/CFPB) Informed Consumer Financial Protection Bureau regarding compliance systems and resources available to community banks and the costs community banks incur to become compliant with various regulations. (Treasury/CFPB)

H.R. 1418 (and S. 509 - renumbered in the Senate to S. 2231) - Small Business Lending Enhancement Act of 2011 (Expansion of credit unions' member business lending powers) (all sections) (House and Senate) H.R. 3993 - Capital Access for Small Business and Jobs Act (Credit union access to outside capital) (all sections) (House and Senate)

Interest penalties for violations of reporting requirements regarding the Small Business Lending Fund (SBLF) (House and Senate and Treasury/SBLF) H.R. 1418 (and S. 509 renumbered in the Senate to S. 2231) - Small Business Lending Enhancement Act of 2011 (Expansion of credit unions member business lending powers) (all sections) (House and Senate) H.R. 3993 Capital Access for Small Business and Jobs Act (Credit union access to outside capital) (all sections) (House and Senate)

Informed House regarding the Consumer Financial Protection Bureau regarding regulatory burden, supervision of non-bank financial service providers, challenges in obtaining credit, tiered regulation, and Small Business Review Panels (House) Informed the Consumer Financial Protection Bureau regarding applicability of rules, positive feedback, consumer responsibility, focus on the largest financial institutions and the shadow financial industry, five year extension of the TAG program, and a Basel III exemption for community banks. (Treasury/CFPB) Informed Consumer Financial Protection Bureau regarding compliance systems and resources available to community banks and the costs community banks incur to become compliant with various regulations. (Treasury/CFPB)

Rein in Significantly Important Financial institution (SIFI) with focused regulation including higher capital and liquidity requirements (House and Senate) Shield community banks from the Dodd-Frank required increase in the deposit insurance fund reserve ratio from 1.15% to 1.35% (House and Senate) Rein in Significantly Important Financial institution (SIFI) with focused regulation including higher capital and liquidity requirements (House and Senate) Shield community banks from the Dodd-Frank required increase in the deposit insurance fund reserve ratio from 1.15% to 1.35% (House and Senate) Consumer Financial Protection - focus on too-big-to-fail banks and financial firms and the shadow financial industry, high standards for consumer compliance required of community banks, accommodation of community banks in serving the needs of their customers, broad definition of covered person, consolidation of RESPA and TILA forms, regulatory compliance and increased regulatory burden, and regulatory relief (House and Senate) Ensure the small debit card issuer exemption in the Dodd-Frank (Durbin Amendment) is working to protect community banks (House and Senate) Downsizing too-big-to-fail banks over a five-years and the regulation of too-big-to-fail banks and financial firms and the shadow financial industry, separation of banking and commerce, expansion of the Volker Rule and restoration of Glass-Steagall Act (House and Senate) Overzealous bank regulatory examinations regulator, senior management, and examiner attitudes and practices, treatment of Commercial Real Estate, excessive write-downs, arbitrary capital requirements, public enforcement actions, reform the appellate process, and community bank closures (House and Senate) Tiered regulation and supervision for community banks (House and Senate) Accounting changes FASB proposed fair value disclosures requiring parenthetical disclosures for all financial instruments carried at amortized cost, PCBOA proposal to expand the scope of the independent accountant during the audit and mandatory auditor rotation, amortizing commercial real estate losses over 10 years for regulatory capital purposes (House and Senate) Secondary mortgage lending reforms curb imprudent lending practices without impacting responsible lenders and loan products designed to meet the diverse needs of community bank customers and their communities (House and Senate) Reform of the housing GSEs - community bank access to a strong, impartial secondary market for residential loans that is financially strong and reliable, privately capitalized cooperative entities with limited mission (House and Senate) Expansion of the Farm Credit System, Rural Community Investments proposal, focus on wholesale funding for community banks and providing correspondent services rather than direct retail competition with community banks (House and Senate) Equitable capital rules which do not disadvantage community banks, higher capital and liquidity requirements for SIFIs, inclusion of accumulated and other comprehensive income in calculation of Tier 1 regulatory capital, and elimination of the 1.25% Allowance for Loan and Lease losses disallowance for regulatory capital purposes) (House and Senate) Overdraft programs uncoordinated regulatory response, address proposed risks with specific banks in the context of the regulatory examination, defer to CFPB (House and Senate) Maintain the Federal Home Loan Bank System and preserve their special functions and purposes (House and Senate) Permanent closing of the ILC loophole (House and Senate) Fairly compensate Fannie and Freddie preferred shareholders by restoring the share value and dividends (House and Senate) H.R. 1697 (and S. 1600) - Communities First Act (Community bank regulatory and tax relief) (all sections) (House and Senate) H.R. 1418 (and S. 509 renumbered in the Senate to S. 2231) - Small Business Lending Enhancement Act of 2011 (Expansion of credit unions member business lending powers) (all sections) (House and Senate) H.R. 3993 Capital Access for Small Business and Jobs Act (Credit union access to outside capital) (all sections) (House and Senate) H.R. 3461 (and 2160) Financial institutions Examination Fairness Act (To improve the examination of depository institutions) (all sections) (House and Senate) Five-year extension of the Transaction Account Guarantee (TAG) program (House and Senate) Comment Letter to the Financial Crimes Enforcement Network (Docket No. FINCEN- 1012-0001 - RIN 1506-AB15) regarding customer dur diligence requirements for community banks (Treasury/FinCEN) Informal comment letter to FDIC regarding community bank regulatory burden, tiered regulation, Transaction Account Guarantee (TAG) program extension, and unfair competition by too-big-to-fail banks and financial firms, credit unions and Farm Credit lenders (FDIC) H.R. 4367 (and S. 2029) ATM fee disclosure legislation to eliminate the duplicative disclosure notices on the exterior of ATM machines (House) Comment Letter to the Securities and Exchange Commission regarding Title VI of the Jumpstart Our Business Startups Act (JOBS Act) regarding deregistration thresholds for thrifts (SEC) Various amendments to the 2012 Farm Bill including: #2156 private sector delivery of crop insurance, #2201 and #2186 limit availability of crop insurance, #2219 conservation compliance with crop insurance, and #2268 USDA guaranteed lending programs (Senate) Comment Letter to the CFPB (Docket No. CFPB-2012-0007) regarding overdrafts and the impact of overdrafts on consumers (Treasury/CFPB) Informed the FDIC-IG (pursuant to their requirements under H.R. 2056) on the causes of bank failures, loss share agreements, and the community impact of bank failures (FDIC/IG)

Secondary mortgage lending reforms curb imprudent lending practices without impacting responsible lenders and loan products designed to meet the diverse needs of community bank customers and their communities (House and Senate) Reform of the housing GSEs - community bank access to a strong, impartial secondary market for residential loans that is financially strong and reliable, privately capitalized cooperative entities with limited mission (House and Senate) Comment Letter to the Financial Crimes Enforcement Network (Docket No. FINCEN- 1012-0001 - RIN 1506-AB15) regarding customer due diligence requirements for community banks (Treasury/FinCEN) H.R. 4367 (and S. 2029) ATM fee disclosure legislation to eliminate the duplicative disclosure notices on the exterior of ATM machines (House) Comment Letter to the CFPB (Docket No. CFPB-2012-0007) regarding overdrafts and the impact of overdrafts on consumers (Treasury/CFPB)

Rein in Significantly Important Financial institution (SIFI) with focused regulation including higher capital and liquidity requirements (House and Senate) Shield community banks from the Dodd-Frank required increase in the deposit insurance fund reserve ratio from 1.15% to 1.35% (House and Senate) Rein in Significantly Important Financial institution (SIFI) with focused regulation including higher capital and liquidity requirements (House and Senate) Shield community banks from the Dodd-Frank required increase in the deposit insurance fund reserve ratio from 1.15% to 1.35% (House and Senate) Consumer Financial Protection - focus on too-big-to-fail banks and financial firms and the shadow financial industry, high standards for consumer compliance required of community banks, accommodation of community banks in serving the needs of their customers, broad definition of covered person, consolidation of RESPA and TILA forms, regulatory compliance and increased regulatory burden, and regulatory relief (House and Senate) Ensure the small debit card issuer exemption in the Dodd-Frank (Durbin Amendment) is working to protect community banks (House and Senate) Downsizing too-big-to-fail banks over a five-years and the regulation of too-big-to-fail banks and financial firms and the shadow financial industry, separation of banking and commerce, expansion of the Volker Rule and restoration of Glass-Steagall Act (House and Senate) Overzealous bank regulatory examinations regulator, senior management, and examiner attitudes and practices, treatment of Commercial Real Estate, excessive write-downs, arbitrary capital requirements, public enforcement actions, reform the appellate process, and community bank closures (House and Senate) Tiered regulation and supervision for community banks (House and Senate) Accounting changes FASB proposed fair value disclosures requiring parenthetical disclosures for all financial instruments carried at amortized cost, PCBOA proposal to expand the scope of the independent accountant during the audit and mandatory auditor rotation, amortizing commercial real estate losses over 10 years for regulatory capital purposes (House and Senate) Secondary mortgage lending reforms curb imprudent lending practices without impacting responsible lenders and loan products designed to meet the diverse needs of community bank customers and their communities (House and Senate) Reform of the housing GSEs - community bank access to a strong, impartial secondary market for residential loans that is financially strong and reliable, privately capitalized cooperative entities with limited mission (House and Senate) Expansion of the Farm Credit System, Rural Community Investments proposal, focus on wholesale funding for community banks and providing correspondent services rather than direct retail competition with community banks (House and Senate) Equitable capital rules which do not disadvantage community banks, higher capital and liquidity requirements for SIFIs, inclusion of accumulated and other comprehensive income in calculation of Tier 1 regulatory capital, and elimination of the 1.25% Allowance for Loan and Lease losses disallowance for regulatory capital purposes) (House and Senate) Overdraft programs uncoordinated regulatory response, address proposed risks with specific banks in the context of the regulatory examination, defer to CFPB (House and Senate) Maintain the Federal Home Loan Bank System and preserve their special functions and purposes (House and Senate) Permanent closing of the ILC loophole (House and Senate) Fairly compensate Fannie and Freddie preferred shareholders by restoring the share value and dividends (House and Senate) H.R. 1697 (and S. 1600) - Communities First Act (Community bank regulatory and tax relief) (all sections) (House and Senate) H.R. 1418 (and S. 509 renumbered in the Senate to S. 2231) - Small Business Lending Enhancement Act of 2011 (Expansion of credit unions member business lending powers) (all sections) (House and Senate) H.R. 3993 Capital Access for Small Business and Jobs Act (Credit union access to outside capital) (all sections) (House and Senate) H.R. 3461 (and 2160) Financial institutions Examination Fairness Act (To improve the examination of depository institutions) (all sections) (House and Senate) Five-year extension of the Transaction Account Guarantee (TAG) program (House and Senate) Comment Letter to the Financial Crimes Enforcement Network (Docket No. FINCEN- 1012-0001 - RIN 1506-AB15) regarding customer dur diligence requirements for community banks (Treasury/FinCEN) Informal comment letter to FDIC regarding community bank regulatory burden, tiered regulation, Transaction Account Guarantee (TAG) program extension, and unfair competition by too-big-to-fail banks and financial firms, credit unions and Farm Credit lenders (FDIC) H.R. 4367 (and S. 2029) ATM fee disclosure legislation to eliminate the duplicative disclosure notices on the exterior of ATM machines (House) Comment Letter to the Securities and Exchange Commission regarding Title VI of the Jumpstart Our Business Startups Act (JOBS Act) regarding deregistration thresholds for thrifts (SEC) Various amendments to the 2012 Farm Bill including: #2156 private sector delivery of crop insurance, #2201 and #2186 limit availability of crop insurance, #2219 conservation compliance with crop insurance, and #2268 USDA guaranteed lending programs (Senate) Comment Letter to the CFPB (Docket No. CFPB-2012-0007) regarding overdrafts and the impact of overdrafts on consumers (Treasury/CFPB) Informed the FDIC-IG (pursuant to their requirements under H.R. 2056) on the causes of bank failures, loss share agreements, and the community impact of bank failures (FDIC/IG)

Secondary mortgage lending reforms curb imprudent lending practices without impacting responsible lenders and loan products designed to meet the diverse needs of community bank customers and their communities Increasing conforming loan limits in the sub-areas of the Chicago metropolitan statistical area (MSA) or in the MSA as a whole

Rein in Significantly Important Financial institution (SIFI) with focused regulation including higher capital and liquidity requirements Shield community banks from the Dodd-Frank required increase in the deposit insurance fund reserve ratio from 1.15% to 1.35% Consumer Financial Protection focus on too-big-to-fail banks and financial firms and shadow financial industry, high standards for consumer compliance required of community banks, accommodation of community banks in serving the needs of their customers, broad definition of covered person, consolidation of RESPA and TILA forms, regulatory compliance and increased regulatory burden, and regulatory relief Ensure the small debit card issuer exemption in the Dodd-Frank (Durbin Amendment) is working to protect community banks Downsizing too-big-to-fail banks over a five-years and the regulation of too-big-to-fail banks and financial firms and the shadow financial industry, separation of banking and commerce, expansion of the Volker Rule and restoration of Glass-Steagall Act Overzealous bank regulatory examinations regulator, senior management, and examiner attitudes and practices, treatment of Commercial Real Estate, excessive write-downs, arbitrary capital requirements, public enforcement actions, reform the appellate process, and community bank closures Tiered regulation and supervision for community banks Accounting changes FASB proposed fair value disclosures requiring parenthetical disclosures for all financial instruments carried at amortized cost, PCBOA proposal to expand the scope of the independent accountant during the audit and mandatory auditor rotation, amortizing commercial real estate losses over 10 years for regulatory capital purposes Secondary mortgage lending reforms curb imprudent lending practices without impacting responsible lenders and loan products designed to meet the diverse needs of community bank customers and their communities Reform of the housing GSEs - community bank access to a strong, impartial secondary market for residential loans that is financially strong and reliable, privately capitalized cooperative entities with limited mission Expansion of the Farm Credit System, Rural Community Investments proposal, focus on wholesale funding for community banks and providing correspondent services rather than direct retail competition with community banks Equitable capital rules which do not disadvantage community banks, higher capital and liquidity requirements for SIFIs, inclusion of accumulated and other comprehensive income in calculation of Tier 1 regulatory capital, and elimination of the 1.25% Allowance for Loan and Lease losses disallowance for regulatory capital purposes) Overdraft programs uncoordinated regulatory response, address proposed risks with specific banks in the context of the regulatory examination, defer to CFPB Maintain the Federal Home Loan Bank System and preserve their special functions and purposes Permanent closing of the ILC loophole Fairly compensate Fannie and Freddie preferred shareholders by restoring the share value and dividends H.R. 1697 (and S. 1600) - Communities First Act (Community bank regulatory and tax relief) (all sections) H.R. 1418 (and S. 509 renumbered in the Senate to S. 2231) - Small Business Lending Enhancement Act of 2011 (Expansion of credit unions member business lending powers) (all sections) H.R. 3993 Capital Access for Small Business and Jobs Act (Credit union access to outside capital) (all sections) H.R. 3461 (and 2160) Financial institutions Examination Fairness Act (To improve the examination of depository institutions) (all sections) H.R. 1365 Capital Access for Main Street Act of 2011 (loan loss amortization) (all sections) Five-year extension of the Transaction Account Guarantee (TAG) program Presidents FY2013 budget request - $61billion fee the largest banks will be assessed to pay for their role in the financial crisis Comment Letter to the U.S. Department of Agriculture regarding the USDAs Rural Business-Cooperative Services interim final rule on Rural Business Investment Companies RIN: 0570-AA80 Comment Letter to the Federal Housing Finance Agency (RIN 2590-AA38) regarding the Agencys proposed rule to amend the community support regulation to require the Federal Home Loan Banks, as opposed to the FHFA, to monitor and assess the eligibility of each FHLBank member for access to long-term advances through compliance with the Community Reinvestment Act of 1977 and first-time homebuyer standards Comment letter to the Board of Governors of the Federal Reserve System (Docket No. 2011-1432 and RIN 7100-AD82), Federal Deposit Insurance Corporation, Treasury/Office of Comptroller of the Currency, and the Securities and Exchange Commission regarding the implementation of Section 619 of the Dodd-Frank Wall Street Reform Act which contains certain prohibitions and restrictions on the ability of a banking entity and nonbank finance companies supervised by the board to engage in propriety trading and have certain interests in, and relationships with, hedge funds and private equity funds Comment letter to the Treasury/Consumer Financial Protection Bureau (Docket No. CFPB-2012-0010 and RIN: 3170-AA20) proposed rule regarding the confidential treatment of privileged information obtained from persons in connection with its exercise of authority under Federal consumer financial law Increasing conforming loan limits in the sub-areas of the Chicago metropolitan statistical area (MSA) or in the MSA as a whole H.R. 3606 Jumpstart Our Business Startups Act (SEC thresholds for registration and deregistration (H.R. 2167 (H.R. 1965) and H.R. 4088) (also H.R. 1070, H.R. 2930 and H.R. 2940)

H.R. 1418 (and S. 509 renumbered in the Senate to S. 2231) - Small Business Lending Enhancement Act of 2011 (Expansion of credit unions member business lending powers) (all sections) H.R. 3993 Capital Access for Small Business and Jobs Act (Credit union access to outside capital) (all sections) Comment Letter to the U.S. Department of Agriculture regarding the USDAs Rural Business-Cooperative Services interim final rule on Rural Business Investment Companies RIN: 0570-AA80

Rein in Significantly Important Financial institution (SIFI) with focused regulation including higher capital and liquidity requirements Shield community banks from the Dodd-Frank required increase in the deposit insurance fund reserve ratio from 1.15% to 1.35% Consumer Financial Protection focus on too-big-to-fail banks and financial firms and shadow financial industry, high standards for consumer compliance required of community banks, accommodation of community banks in serving the needs of their customers, broad definition of covered person, consolidation of RESPA and TILA forms, regulatory compliance and increased regulatory burden, and regulatory relief Ensure the small debit card issuer exemption in the Dodd-Frank (Durbin Amendment) is working to protect community banks Downsizing too-big-to-fail banks over a five-years and the regulation of too-big-to-fail banks and financial firms and the shadow financial industry, separation of banking and commerce, expansion of the Volker Rule and restoration of Glass-Steagall Act Overzealous bank regulatory examinations regulator, senior management, and examiner attitudes and practices, treatment of Commercial Real Estate, excessive write-downs, arbitrary capital requirements, public enforcement actions, reform the appellate process, and community bank closures Tiered regulation and supervision for community banks Accounting changes FASB proposed fair value disclosures requiring parenthetical disclosures for all financial instruments carried at amortized cost, PCBOA proposal to expand the scope of the independent accountant during the audit and mandatory auditor rotation, amortizing commercial real estate losses over 10 years for regulatory capital purposes Secondary mortgage lending reforms curb imprudent lending practices without impacting responsible lenders and loan products designed to meet the diverse needs of community bank customers and their communities Reform of the housing GSEs - community bank access to a strong, impartial secondary market for residential loans that is financially strong and reliable, privately capitalized cooperative entities with limited mission Expansion of the Farm Credit System, Rural Community Investments proposal, focus on wholesale funding for community banks and providing correspondent services rather than direct retail competition with community banks Equitable capital rules which do not disadvantage community banks, higher capital and liquidity requirements for SIFIs, inclusion of accumulated and other comprehensive income in calculation of Tier 1 regulatory capital, and elimination of the 1.25% Allowance for Loan and Lease losses disallowance for regulatory capital purposes) Overdraft programs uncoordinated regulatory response, address proposed risks with specific banks in the context of the regulatory examination, defer to CFPB Maintain the Federal Home Loan Bank System and preserve their special functions and purposes Permanent closing of the ILC loophole Fairly compensate Fannie and Freddie preferred shareholders by restoring the share value and dividends H.R. 1697 (and S. 1600) - Communities First Act (Community bank regulatory and tax relief) (all sections) H.R. 1418 (and S. 509 renumbered in the Senate to S. 2231) - Small Business Lending Enhancement Act of 2011 (Expansion of credit unions member business lending powers) (all sections) H.R. 3993 Capital Access for Small Business and Jobs Act (Credit union access to outside capital) (all sections) H.R. 3461 (and 2160) Financial institutions Examination Fairness Act (To improve the examination of depository institutions) (all sections) H.R. 1365 Capital Access for Main Street Act of 2011 (loan loss amortization) (all sections) Five-year extension of the Transaction Account Guarantee (TAG) program Presidents FY2013 budget request - $61billion fee the largest banks will be assessed to pay for their role in the financial crisis Comment Letter to the U.S. Department of Agriculture regarding the USDAs Rural Business-Cooperative Services interim final rule on Rural Business Investment Companies RIN: 0570-AA80 Comment Letter to the Federal Housing Finance Agency (RIN 2590-AA38) regarding the Agencys proposed rule to amend the community support regulation to require the Federal Home Loan Banks, as opposed to the FHFA, to monitor and assess the eligibility of each FHLBank member for access to long-term advances through compliance with the Community Reinvestment Act of 1977 and first-time homebuyer standards Comment letter to the Board of Governors of the Federal Reserve System (Docket No. 2011-1432 and RIN 7100-AD82), Federal Deposit Insurance Corporation, Treasury/Office of Comptroller of the Currency, and the Securities and Exchange Commission regarding the implementation of Section 619 of the Dodd-Frank Wall Street Reform Act which contains certain prohibitions and restrictions on the ability of a banking entity and nonbank finance companies supervised by the board to engage in propriety trading and have certain interests in, and relationships with, hedge funds and private equity funds Comment letter to the Treasury/Consumer Financial Protection Bureau (Docket No. CFPB-2012-0010 and RIN: 3170-AA20) proposed rule regarding the confidential treatment of privileged information obtained from persons in connection with its exercise of authority under Federal consumer financial law Increasing conforming loan limits in the sub-areas of the Chicago metropolitan statistical area (MSA) or in the MSA as a whole H.R. 3606 Jumpstart Our Business Startups Act (SEC thresholds for registration and deregistration (H.R. 2167 (H.R. 1965) and H.R. 4088) (also H.R. 1070, H.R. 2930 and H.R. 2940)

H.R. 1697 (and S. 1600) - Communities First Act (Community bank regulatory and tax relief) (all sections) H.R. 1418 (and S. 509) - Small Business Lending Enhancement Act of 2011 (Expansion of credit unions member business lending powers) (all sections) Proposed Department of Housing and Urban Development (HUD) Rule to amend HUD regulations to enable the direct lending institutions of the Farm Credit System (FCS) to seek approval to participate in the Federal Housing Administration (FHA) mortgage insurance programs as approved mortgagees and lenders Docket No. FR-5416-P; RIN 2502-AI91 H.R. 1965 and (S. 556) Amend Securities Laws to Establish Certain Thresholds for Shareholder Registration (all sections) H.R. 2167 - Private Company Flexibility and Growth Act (To amend the SEC Act of 1934 to change the threshold number of shareholders for required registration under the Act) (all sections) H.R. 2940 Access to Capital for Jobs Creators Act (To direct the SEC to eliminate the prohibition against general solicitation as a requirement for a certain exemption under Regulation D) (all sections) Bank checking account disclosures H.R. 3213 Small Company Jobs Growth and Regulatory Relief Act of 2011 (To amend the Sarbanes-Oxley Act of 2002 to provide additional exemptions from the internal control auditing requirements for smaller and newer public companies) (all sections) H.R. 3461 Financial institutions Examination Fairness Act (To improve the examination of depository institutions) (all sections) Foreclosed and abandoned property - security and maintenance

H.R. 1697 (and S. 1600) - Communities First Act (Community bank regulatory and tax relief) (all sections) Proposed Department of Housing and Urban Development (HUD) Rule to amend HUD regulations to enable the direct lending institutions of the Farm Credit System (FCS) to seek approval to participate in the Federal Housing Administration (FHA) mortgage insurance programs as approved mortgagees and lenders Docket No. FR-5416-P; RIN 2502-AI91

H.R. 1697 (and S. 1600) - Communities First Act (Community bank regulatory and tax relief) (all sections) H.R. 1418 (and S. 509) - Small Business Lending Enhancement Act of 2011 (Expansion of credit unions' member business lending powers) (all sections) H.R. 1965 and (S. 556) - Amend Securities Laws to Establish Certain Thresholds for Shareholder Registration (all sections) H.R. 2167 - Private Company Flexibility and Growth Act (To amend the SEC Act of 1934 to change the threshold number of shareholders for required registration under the Act) (all sections) H.R. 2940 Access to Capital for Jobs Creators Act (To direct the SEC to eliminate the prohibition against general solicitation as a requirement for a certain exemption under Regulation D) (all sections) H.R. 3213 Small Company Jobs Growth and Regulatory Relief Act of 2011 (To amend the Sarbanes-Oxley Act of 2002 to provide additional exemptions from the internal control auditing requirements for smaller and newer public companies) (all sections)

H.R. 1697 (and S. 1600) - Communities First Act (Community bank regulatory and tax relief) (all sections) H.R. 1418 (and S. 509) - Small Business Lending Enhancement Act of 2011 (Expansion of credit unions member business lending powers) (all sections) Proposed Department of Housing and Urban Development (HUD) Rule to amend HUD regulations to enable the direct lending institutions of the Farm Credit System (FCS) to seek approval to participate in the Federal Housing Administration (FHA) mortgage insurance programs as approved mortgagees and lenders Docket No. FR-5416-P; RIN 2502-AI91 H.R. 1965 and (S. 556) Amend Securities Laws to Establish Certain Thresholds for Shareholder Registration (all sections) H.R. 2167 - Private Company Flexibility and Growth Act (To amend the SEC Act of 1934 to change the threshold number of shareholders for required registration under the Act) (all sections) H.R. 2940 Access to Capital for Jobs Creators Act (To direct the SEC to eliminate the prohibition against general solicitation as a requirement for a certain exemption under Regulation D) (all sections) Bank checking account disclosures H.R. 3213 Small Company Jobs Growth and Regulatory Relief Act of 2011 (To amend the Sarbanes-Oxley Act of 2002 to provide additional exemptions from the internal control auditing requirements for smaller and newer public companies) (all sections) H.R. 3461 Financial institutions Examination Fairness Act (To improve the examination of depository institutions) (all sections) Foreclosed and abandoned property - security and maintenance

H.R. 1697 - Communities First Act (all sections) Farm Credit Systems Rural Community Investment proposal

H.R. 1697 - Communities First Act (all sections) Federal Regulation "Z" - mortgage escrow requirement exemptions ORM - Qualified Residential Mortgages Proposed Guidance on Deposit-Related Consumer Credit Products Docket ID OCC-2011-0012 New CFPB RESPA and TILA forms and Islamic lending

H.R. 1697 - Communities First Act (all sections) Federal Regulation "Z" - mortgage escrow requirement exemptions H.R. 1723 - Common Sense Economic Recovery Act (all sections) H.R. 2056 - Examine the Regulatory Examination Environment (all sections) H.R. 1356 Capital Access to Main Street Act (all sections) QRM Qualified Residential Mortgages Implementation of the Small Business Lending Fund (SBLF) including dividend restrictions and funding delays Farm Credit Systems Rural Community Investment proposal Proposed Guidance on Deposit-Related Consumer Credit Products - Docket ID OCC-2011-0012 New CFPB RESPA and TILA forms and Islamic lending H.R. 1418 (and S. 509) - Small Business Lending Enhancement Act of 2011 (Expansion of credit unions member business lending powers) H.R. 1249 (and S. 23) - Leahy-Smith America Invents Act (Section 18 only) Fair lending actions and Community Reinvestment Act (CRA)

H.R. 1697 - Communities First Act (all sections) H.R. 1418 (and S. 509) - Small Business Lending Enhancement Act of 2011 (Expansion of credit unions member business lending powers)

H.R. 1697 - Communities First Act (all sections) H.R. 1723 Common Sense Economic Recovery Act (all sections) Implementation of the Small Business Lending Fund (SBLF) including dividend restrictions and funding delays

S. 712 - Financial Takeover Repeal Act of 2011 (Repeal of Dodd Frank Act) H.R. 1081 - Consumers Payment System Protection Act (Delay and Study of debit interchange regulation) S 575 - Debit Interchange Fee Study Act of 2011(Delay and study of debit interchange regulation) S.AMDT.392 - To improve the regulatory structure for electronic debit card transactions, and for other purposes (Delay and study of debit interchange regulation) H.R. 1697 - Communities First Act (all, including tiered supervision and regulation of community banks) Consumer Financial Protection Bureau focus on too-big-to-fail banks and financial firms and shadow financial industry, the high standards for consumer compliance required of community banks, accommodation of community banks in serving the needs of their customers, avoid hindering product innovation and customer service, regulatory compliance and increased regulatory burden, and regulatory relief Reform of the housing GSEs (community bank access to the secondary residential mortgage market) and the Federal Home Loan Bank (FHLB) system's place in the reform of the housing GSEs Overdraft programs Guidance, ad hoc clarifications, customer notifications, regulatory examinations and CAMELS downgrades Merchants data breaches Federal Regulation Z mortgage escrow requirement exemptions QRM Qualified Residential Mortgages

H.R. 4 - Comprehensive 1099 Taxpayer Protection and Repayment of Exchange Subsidy Overpayments Act of 2011 (Repeal of 1099 reporting requirements) S. 712 - Financial Takeover Repeal Act of 2011 (Repeal of Dodd Frank Act) H.R. 1081 - Consumers Payment System Protection Act (Delay and Study of debit interchange regulation) S 575 - Debit Interchange Fee Study Act of 2011(Delay and study of debit interchange regulation) S.AMDT.392 - To improve the regulatory structure for electronic debit card transactions, and for other purposes (Delay and study of debit interchange regulation) H.R. 1418 - Small Business Lending Enhancement Act of 2011 (Expansion of credit unions commercial lending powers) S. 509 - Small Business Lending Enhancement Act of 2011 (Expansion of credit unions commercial lending powers) Farm Credit Administration (FCA) - Federal Credit Service (FCS) lenders bidding on loans of failed banks from the FDIC Farm Credit Systems Rural Community Investment proposal Implementation of the Small Business Lending Fund (SBLF) including dividend restrictions and funding delays H.R. 1697 - Communities First Act (all, including tiered supervision and regulation of community banks) H.R. 1249 - Leahy-Smith America Invents Act (Section 18 only) QRM Qualified Residential Mortgages Consumer Financial Protection Bureau focus on too-big-to-fail banks and financial firms and shadow financial industry, the high standards for consumer compliance required of community banks, accommodation of community banks in serving the needs of their customers, avoid hindering product innovation and customer service, regulatory compliance and increased regulatory burden, and regulatory relief FDIC Insurance reforms - implementation of assessment base change, Deposit Insurance Fund (DIF), premium rates, restoration of target reserve ratios, permanent extension of the Transaction Account Guarantee (TAG) program Regulation of too-big-to-fail banks and financial firms and the shadow financial industry, separation of banking and commerce, expansion of the Volker Rule and restoration of Glass-Steagall Act Overzealous bank regulatory examinations - regulators senior management and examiner attitudes and practices, treatment of Commercial Real Estate, excessive write-downs, arbitrary capital requirements, public enforcement actions, and community bank closures Accounting changes - mark-to-market, amortizing commercial real estate losses over 10 years for regulatory capital purposes, and elimination of the 1.25% Allowance for Loan and Lease losses disallowance for regulatory capital purposes) Reform of the housing GSEs - community bank access to the secondary residential mortgage market, and the Federal Home Loan Bank (FHLB) system's place in the reform of the housing GSEs Common sense lending Permanent closing of the ILC loophole Overdraft programs - Guidance, ad hoc clarifications, customer notifications, regulatory examinations and CAMELS downgrades Compensation of Fannie and Freddie preferred shareholders Equitable capital rules for community banks (Basel III) Dodd Frank Brokered Deposit Study (Comment Letter) Repeal of Federal Regulation Q (interest on demand deposits) in the Dodd Frank Act Merchants data breaches Federal Regulation Z mortgage escrow requirement exemptions Revisions to the new FHLB-C Advances, Collateral Pledge and Security Agreement

H.R. 4 - Comprehensive 1099 Taxpayer Protection and Repayment of Exchange Subsidy Overpayments Act of 2011 (Repeal of 1099 reporting requirements) S. 712 - Financial Takeover Repeal Act of 2011 (Repeal of Dodd Frank Act) H.R. 1081 - Consumers Payment System Protection Act (Delay and Study of debit interchange regulation) S 575 - Debit Interchange Fee Study Act of 2011(Delay and study of debit interchange regulation) S.AMDT.392 - To improve the regulatory structure for electronic debit card transactions, and for other purposes (Delay and study of debit interchange regulation) H.R. 1418 - Small Business Lending Enhancement Act of 2011 (Expansion of credit unions commercial lending powers) S. 509 - Small Business Lending Enhancement Act of 2011 (Expansion of credit unions commercial lending powers) Farm Credit Administration (FCA) - Federal Credit Service (FCS) lenders bidding on loans of failed banks from the FDIC Farm Credit Systems Rural Community Investment proposal Implementation of the Small Business Lending Fund (SBLF) including dividend restrictions and funding delays H.R. 1697 - Communities First Act (all, including tiered supervision and regulation of community banks) H.R. 1249 - Leahy-Smith America Invents Act (Section 18 only) QRM Qualified Residential Mortgages Consumer Financial Protection Bureau focus on too-big-to-fail banks and financial firms and shadow financial industry, the high standards for consumer compliance required of community banks, accommodation of community banks in serving the needs of their customers, avoid hindering product innovation and customer service, regulatory compliance and increased regulatory burden, and regulatory relief FDIC Insurance reforms - implementation of assessment base change, Deposit Insurance Fund (DIF), premium rates, restoration of target reserve ratios, permanent extension of the Transaction Account Guarantee (TAG) program Regulation of too-big-to-fail banks and financial firms and the shadow financial industry, separation of banking and commerce, expansion of the Volker Rule and restoration of Glass-Steagall Act Overzealous bank regulatory examinations - regulators senior management and examiner attitudes and practices, treatment of Commercial Real estate, excessive write-downs, arbitrary capital requirements, public enforcement actions, and community bank closures Accounting changes - mark-to-market, amortizing commercial real estate losses over 10 years for regulatory capital purposes, and elimination of the 1.25% Allowance for Loan and Lease losses disallowance for regulatory capital purposes) Reform of the housing GSEs - community bank access to the secondary residential mortgage market, and the Federal Home Loan Bank (FHLB) system's place in the reform of the housing GSEs Common sense lending Permanent closing of the ILC loophole Overdraft programs - Guidance, ad hoc clarifications, customer notifications, regulatory examinations and CAMELS downgrades Compensation of Fannie and Freddie preferred shareholders Equitable capital rules for community banks (Basel III) Dodd Frank Brokered Deposit Study (Comment Letter) Repeal of Federal Regulation Q (interest on demand deposits) in the Dodd Frank Act Merchants data breaches Federal Regulation Z mortgage escrow requirement exemptions Revisions to the new FHLB-C Advances, Collateral Pledge and Security Agreement

Farm Credit Administration (FCA) - Federal Credit Service (FCS) lenders bidding on loans of failed banks from the FDIC Farm Credit Systems Rural Community Investment proposal

Debit Interchange - concept, rate, impact on community banks, H.R. 1081 and S. 575 delay and study, groups supporting and opposing Regulation of too-big-to-fail banks and financial firms and shadow financial industry Overzealous bank regulatory examinations - senior management and examiner attitudes and practices, treatment of Commercial Real Estate, excessive writedowns, arbitrary capital requirements, public enforcement actions, and community bank closures Consumer Financial Protection Bureau - focus on too-big-to-fail banks and financial firms and shadow financial industry, standards required by community banks, regulatory compliance and increased regulatory burden, regulatory relief, consumer disclosure forms, level competitive playing field, community bank access to secondary mortgage markets, mortgage servicing and residential mortgage foreclosures, community bank image, and product innovation and customer service Separation of banking and commerce, Volker Rule and restoration of Glass-Steagall FASB's Mark-to-Market accounting standards, amortization of Commercial Real Estate (CRE) losses over 10 years (for regulatory accounting purposes only), 1.25% Allowance for Loan and Lease Losses (ALLL) disallowance for regulatory capital purposes Future and reform of the housing Government Sponsored Entities (GSEs), community bank access to secondary mortgage markets, and the Federal Home Loan Bank systems place in the reform of the GSEs Farm Credit System (FCS) - Rural Community Investment proposal Credit union tax exemption, expanded powers - S. 509 Small Business Lending Enhancement Act ILC loophole Compensation for Fannie and Freddie preferred shareholders Overdraft programs - guidance, ad hoc clarification, customer notifications, regulatory examination and CAMELS downgrades FDIC Insurance IOLTA coverage, implement assessment base change, premium rates, Deposit Insurance Fund (DIF) restoration, and target reserve ratios Basel III capital requirements $30 billion Small Business Lending Fund - implementation, delays, status of all types of applications, approvals, and fundings Tiered bank regulation for community banks H.R. 4 the Small Business Paperwork Mandate Elimination Act of 2011- repeal of 1099 reporting requirements Mortgage Servicers - proposed regulatory enforcement actions Federal Housing Finance Agencys (FHFAs) Advance Notice of Proposed Rulemaking (ANPR) - proposed changes to Federal Home Loan Bank membership requirements

Debit Interchange - concept, rate, impact on community banks, H.R. 1081 and S. 575 delay and study, groups supporting and opposing Regulation of too-big-to-fail banks and financial firms and shadow financial industry Overzealous bank regulatory examinations - senior management and examiner attitudes and practices, treatment of Commercial Real Estate, excessive writedowns, arbitrary capital requirements, public enforcement actions, and community bank closures Consumer Financial Protection Bureau - focus on too-big-to-fail banks and financial firms and shadow financial industry, standards required by community banks, regulatory compliance and increased regulatory burden, regulatory relief, consumer disclosure forms, level competitive playing field, community bank access to secondary mortgage markets, mortgage servicing and residential mortgage foreclosures, community bank image, and product innovation and customer service Separation of banking and commerce, Volker Rule and restoration of Glass-Steagall FASB's Mark-to-Market accounting standards, amortization of Commercial Real Estate (CRE) losses over 10 years (for regulatory accounting purposes only), 1.25% Allowance for Loan and Lease Losses (ALLL) disallowance for regulatory capital purposes Future and reform of the housing Government Sponsored Entities (GSEs), community bank access to secondary mortgage markets, and the Federal Home Loan Bank systems place in the reform of the GSEs Farm Credit System (FCS) - Rural Community Investment proposal Credit union tax exemption, expanded powers - S. 509 Small Business Lending Enhancement Act ILC loophole Compensation for Fannie and Freddie preferred shareholders Overdraft programs - guidance, ad hoc clarification, customer notifications, regulatory examination and CAMELS downgrades FDIC Insurance IOLTA coverage, implement assessment base change, premium rates, Deposit Insurance Fund (DIF) restoration, and target reserve ratios Basel III capital requirements $30 billion Small Business Lending Fund - implementation, delays, status of all types of applications, approvals, and fundings Tiered bank regulation for community banks H.R. 4 the Small Business Paperwork Mandate Elimination Act of 2011- repeal of 1099 reporting requirements Mortgage Servicers - proposed regulatory enforcement actions Federal Housing Finance Agencys (FHFAs) Advance Notice of Proposed Rulemaking (ANPR) - proposed changes to Federal Home Loan Bank membership requirements

Debit Interchange - concept, rate, impact on community banks, H.R. 1081 and S. 575 delay and study, groups supporting and opposing $30 billion Small Business Lending Fund - implementation, delays, status of all types of applications, approvals, and fundings H.R. 4 the Small Business Paperwork Mandate Elimination Act of 2011- repeal of 1099 reporting requirements

Wholesale Credit Union failures (3) and government bailout Farm Credit Administration (FCA) - FCS lenders bidding on FDIC loan purchases from failed banks Residential mortgage foreclosures Expiring tax measures or "tax extenders" HR 6398 - IOLTA deposit insurance coverage under the TAG program S 3221 Waive USDA term limits through 2012 HR 5297 Small Business Jobs Act and the $30 billion Small Business Lending Fund Credit Union tax exemption FASBs proposed mark-to-market accounting rule change Future of the housing GSEs, key principals in the reform of Fannie, Freddie and the FHLB FDIC loss sharing agreements - loan participations - lead banks and participants Consumer Financial Protection Bureau (CFPB) - large banks & financial firms and shadow financial industry, community bank exemptions and regulatory relief

Residential mortgage foreclosures Expiring tax measures or "tax extenders" Consumer Financial Protection Bureau (CFPB) - large banks & financial firms and shadow financial industry, community bank exemptions and regulatory relief

Expiring tax measures or "tax extenders" HR 5297 Small Business Jobs Act and the $30 billion Small Business Lending Fund

Small Business Jobs Act (HR 5297), $30 billion Small Business Lending Fund, SBA provisions, Subchapter "S" provisions, expensing and depreciation, export and trade finance incentives, credit union expansion of business lending capabilities, loan loss amortization Bank regulatory enforcement actions and their publication, harsh regulatory examinations, asset risk weights percentages for GSEs securities and the impact on regulatory capital, Trust Preferred Securities and the impact on regulatory capital FASBs proposed mark-to-market accounting rule change Dodd-Frank Wall Street Reform and Consumer Protection Act (HR 4173 and S 3217), asset-based deposit insurance assessments, too-big-to-fail banks and financial institutions (TBTF) and systemic risk, Consumer Financial Protection Bureau (CFPB), CFPB rule writing, examination, enforcement and exemption for community banks, deposit insurance limit increases, Transaction Account Guarantee (TAG) extension, SOX Section 404(b) exemption of auditor attestation requirement, Volker Rule, Industrial Loan Companies (ILCs) moritorium, Trust Preferred Securities, 5% risk-retention rule, "qualified loans" mortgage underwriting, derivatives rules, large-bank FDIC premiums, FHLB concentration limits, Durbin debit interchange amendment, auto dealer CFPB exemption, executive compensation, bank holding company (BHC) risk committees, expanded affiliate transaction rules, insider trading rules, "source of strength" rules for BHCs FHLB double assessment secured liability adjustment Future of the housing GSEs, key principals in the reform of Fannie, Freddie and the FHLB Protecting Homeowners Credit History Act (HR 5743), accurate reporting of credit histories Proposed Commercial Real Estate Stabilization Act (CRESA) securitize commercial real estate loans and other real estete owned (OREO) Capped versus full residential mortgage interest deduction

Small Business Jobs Act (HR 5297), $30 billion Small Business Lending Fund, SBA provisions, Subchapter "S" provisions, expensing and depreciation, export and trade finance incentives, credit union expansion of business lending capabilities, loan loss amortization

Dodd-Frank Wall Street Reform and Consumer Protection Act (HR 4173 and S 3217), Consumer Financial Protection Bureau (CFPB) rule writing, examination, enforcement and exemption for community banks

H.R. 5297 - Small Business Jobs and Credit Act of 2010, $30B small business lending fund, community bank access, restrictions and eligibility requirements, including the Perlmutter Amendment regarding Loan Loss Amortization Proposed change to banking regulation requiring banks to exclude, for regulatory capital purposes, Allowance for Loan and Lease Losses (ALLL) in excess of 1.25% of Risk Weighted Assets Consideration and passage of H.R. 4173 and S 3217 the Dodd-Frank Act All titles to the Dodd-Frank Act relating to community banks Too-big-to-fail banks and financial institutions (TBTF), systemic risk and systemic risk regulator, $150 billion prefunded Systemic Risk Fund, national deposit concentration cap, and resolution authority FDIC Insurance Assessment method revision: Gutierrez Amendment in the House bill and Tester-Hutchinson Amendment in the Senate bill Extension of the Transaction Account Guarantee (TAG) component of the Temporary Liquidity Guarantee Program (TGLP) for an additional twelve months Two year Extension of the Transaction Account Guarantee Program (TAG) Permanent increase in deposit insurance to $250,000.00 Fair Value or Mark-to-Market Standards The Dual Banking System and Charter Choice The role of the Federal Reserve Bank, monetary policy and supervision authority for state-chartered banks and holding companies Separation of Banking and Commerce, Glass-Steagall Act, the "Volker Rule" The Consumer Financial Protection Agency/Bureau, housing the CFPB in the Federal Reserve Bank, the regulation of too-big-to-fail (TBTF) financial institutions and the shadow financial industry, auto dealer exemption, exemption from examination and enforcement for community banks Collins Amendment regarding trust preferred securities, exemptions for community banks 5% risk retention for residential mortgage loans, exemption for low risk residential mortgages The Federal Home Loan Bank System's functions and purposes, and as a source of liquidity/funding for community banks Bank regulatory examinations, capital standards, loan valuations, loan loss reserve policies, commercial real estate concentration guidance, small business lending Farm Credit System's (FCS) "Rural Community Investment" Expansion of credit union business lending authority, raising the lending cap to 25%, excluding loans under $250K from the cap Durbin Interchange Amendment ATM surcharge cap Thrift charter preservation Exemption for small publicly held companies from Sarbains-Oxley 404(b) auditor attestation requirement New industrial loan company (ILC) moratorium National bank lending limits for state-chartered bank $19B "Pay For" amendment to the Dodd-Frank Act, exemption for community banks Regulation and oversight of the Derivatives Market Assistant Secretary of Treasury for Community Financial Institutions Proposed legislation regarding increased Certificate of Deposit interest exemptions for individual and married filers Bank regulatory enforcement actions and their publication Brokered deposit restrictions Proposed legislation to securitize commercial real estate (CRE) loans and securitize seriously delinquent CRE loans and other real estate owned (OREO) Proposal to decrease Risk Weight percentage for debt and mortgage-backed securities (MBS) of Fannie Mae and Freddie Mac and Federal Home Loan Banks (FHLBs) from 20% to 10% for determining Risk Weighted Assets (RWA) in determining bank capital ratios

H.R. 5297 - Small Business Jobs and Credit Act of 2010, $30B small business lending fund, community bank access, restrictions and eligibility requirements, including the Perlmutter Amendment regarding Loan Loss Amortization Proposed change to banking regulation requiring banks to exclude, for regulatory capital purposes, Allowance for Loan and Lease Losses (ALLL) in excess of 1.25% of Risk Weighted Assets Consideration and passage of H.R. 4173 and S 3217 the Dodd-Frank Act All titles to the Dodd-Frank Act relating to community banks Too-big-to-fail banks and financial institutions (TBTF), systemic risk and systemic risk regulator, $150 billion prefunded Systemic Risk Fund, national deposit concentration cap, and resolution authority FDIC Insurance Assessment method revision: Gutierrez Amendment in the House bill and Tester-Hutchinson Amendment in the Senate bill Extension of the Transaction Account Guarantee (TAG) component of the Temporary Liquidity Guarantee Program (TGLP) for an additional twelve months Two year Extension of the Transaction Account Guarantee Program (TAG) Permanent increase in deposit insurance to $250,000.00 Fair Value or Mark-to-Market Standards The Dual Banking System and Charter Choice The role of the Federal Reserve Bank, monetary policy and supervision authority for state-chartered banks and holding companies Separation of Banking and Commerce, Glass-Steagall Act, the "Volker Rule" The Consumer Financial Protection Agency/Bureau, housing the CFPB in the Federal Reserve Bank, the regulation of too-big-to-fail (TBTF) financial institutions and the shadow financial industry, auto dealer exemption, exemption from examination and enforcement for community banks Collins Amendment regarding trust preferred securities, exemptions for community banks 5% risk retention for residential mortgage loans, exemption for low risk residential mortgages The Federal Home Loan Bank System's functions and purposes, and as a source of liquidity/funding for community banks Bank regulatory examinations, capital standards, loan valuations, loan loss reserve policies, commercial real estate concentration guidance, small business lending Farm Credit System's (FCS) "Rural Community Investment" Expansion of credit union business lending authority, raising the lending cap to 25%, excluding loans under $250K from the cap Durbin Interchange Amendment ATM surcharge cap Thrift charter preservation Exemption for small publicly held companies from Sarbains-Oxley 404(b) auditor attestation requirement New industrial loan company (ILC) moratorium National bank lending limits for state-chartered bank $19B "Pay For" amendment to the Dodd-Frank Act, exemption for community banks Regulation and oversight of the Derivatives Market Assistant Secretary of Treasury for Community Financial Institutions Proposed legislation regarding increased Certificate of Deposit interest exemptions for individual and married filers Bank regulatory enforcement actions and their publication Brokered deposit restrictions Proposed legislation to securitize commercial real estate (CRE) loans and securitize seriously delinquent CRE loans and other real estate owned (OREO) Proposal to decrease Risk Weight percentage for debt and mortgage-backed securities (MBS) of Fannie Mae and Freddie Mac and Federal Home Loan Banks (FHLBs) from 20% to 10% for determining Risk Weighted Assets (RWA) in determining bank capital ratios

Proposed legislation regarding increased Certificate of Deposit interest exemptions for individual and married filers

Consumer Financial Protection Agency (CFPA), its focus on the too-big-to-fail (TBTF) banks and the "shadow' financial industry, rule writing, examination and enforcement, and exemption for community banks New Provision to Regulation "Z" requiring escrow accounts for "higher-priced" mortgages "Move your Money" campaign to move deposits from TBTF banks to community banks S 3217 Restoring Financial Stability Act of 2010, all provisions relating to community banks

Proposed $30 Billion Small Business Lending Fund legislation, community bank access, restrictions and eligibilility requirements

Proposed $30 Billion Small Business Lending Fund, community bank access, restrictions and eligibilility requirements Proposed change to banking regulation requiring banks to exclude, for regulatory capital purposes, Allowance for Loan and Lease Losses (ALLL) in excess of 1.25% of Risk Weighted Assets Proposed change in TARP requirements for community banks from proving viability before the addition of capital funds to after the addition of capital funds Bank regulatory enforcement actions and their publication, harsh regulatory examinations, brokered deposit restrictions Too-big-to-fail banks and financial Institutions (TBTF) The reform of FDIC Insurance Assessments Preserving the Dual Banking System and Charter Choice Separating Banking and Commerce, Restoring Glass-Steagal, the proposed Volker Rule to financial reform legislation Proposed legislation regarding 10-Year Loan Loss Amortization New Role for the Federal Reserve Bank, monetary policy and regulator for state-chartered banks Modernization of Regulation and oversight of the Derivatives Market New Provision to Regulation "Z" requiring escrow accounts for "higher-priced" mortgages Proposed legislation to securitize commercial real estate (CRE) loans and securitize seriously delinquent CRE loans and other real estate owned (OREO) Prefunded Systemic Risk Fund at $150B in financial reform legislation Proposal to decrease Risk Weight percentage for debt and mortgage-backed securities (MBS) of Fannie Mae and Freddie Mac and Federal Home Loan Banks (FHLBs) from 20% to 10% for determining Risk Weighted Assets (RWA) in determining bank capital ratios Extension of the Transaction Account Guarantee (TAG) component of the Temporary Liquidity Guarantee Program (TGLP) for an additional twelve months H.R. 3380 and S 2919 - Promoting Lending to America's Small Business Act of 2009 (and-or other legislative vehicles), all provisions including expanision of credit union business lending authority, raising the lending cap to 25%, excluding loans under $250K from the cap "Move your Money" campaign to move deposits from TBTF banks to community banks S 3217 Restoring Financial Stability Act of 2010, all provisions relating to community banks

Currently, HR 4173 Wall Street Reform and Consumer Protection Act, and the proposed Senate Bill - Restoring American Financial Stability Act, all relevant provisions relating to their impact on Illinois community banks and thrifts. Prospectively, all federal legislation and regulation potentially impacting Illinois community banks and thrifts.

Currently, HR 4173 Wall Street Reform and Consumer Protection Act, and the proposed Senate Bill - Restoring American Financial Stability Act, all relevant provisions relating to their impact on Illinois community banks and thrifts. Prospectively, all federal legislation and regulation potentially impacting Illinois community banks and thrifts.

Currently, HR 4173 Wall Street Reform and Consumer Protection Act, and the proposed Senate Bill - Restoring American Financial Stability Act, all relevant provisions relating to their impact on Illinois community banks and thrifts. Prospectively, all federal legislation and regulation potentially impacting Illinois community banks and thrifts.

Currently, HR 4173 Wall Street Reform and Consumer Protection Act, and the proposed Senate Bill - Restoring American Financial Stability Act, all relevant provisions relating to their impact on Illinois community banks and thrifts. Prospectively, all federal legislation and regulation potentially impacting Illinois community banks and thrifts.

Currently, HR 4173 Wall Street Reform and Consumer Protection Act, and the proposed Senate Bill - Restoring American Financial Stability Act, all relevant provisions relating to their impact on Illinois community banks and thrifts. Prospectively, all federal legislation and regulation potentially impacting Illinois community banks and thrifts.

Currently, HR 4173 Wall Street Reform and Consumer Protection Act, and the proposed Senate Bill - Restoring American Financial Stability Act, all relevant provisions relating to their impact on Illinois community banks and thrifts. Prospectively, all federal legislation and regulation potentially impacting Illinois community banks and thrifts.