Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page

9. Check if this filing amends a previously filed version of this report

LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code BAN

16. Specific lobbying issues

Protect the credit union tax exemption;
Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members;
Support regulatory relief for credit unions;
Provide guidance or rulemakings rather than rule through enforcement;
Support increase in funding for CDFI Fund, MDIs, and the CDRLF;
Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight;
Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies;
Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members;
Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper;
Support extending GLBA like data security measures to retailers;
Support recognizing GLBA compliance in any privacy legislation;
Oppose SBA direct lending authority;
Support improvements to ease the process for forgiveness of PPP loans to small businesses;
Oppose limits on fee income for credit unions including courtesy pay;
Support CFPB study of overdraft programs to determine the value to consumers;
Support limiting burdens of HMDA rule on credit unions;
CFPB should remove unnecessary and unused data points related to HMDA reporting;
Support permanently increasing reporting thresholds for open- and closed-end loans;
Prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products;
CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate;
CFPB should engage in interagency coordination on Section 1033 consumer access to financial records rulemaking;
Oppose CFPBs characterization of regulated and disclosed financial services fees as junk fees;
CFPB should explore streamlining required fee disclosures;
CFPB should clarify UDAAP authority;
CFPB should respect GLBAs data security regulatory structure;
CFPB should limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09);
Improve examination coordination between CFPB and NCUA;
Support permanent adoption of CFPBs expired temporary relief of E-SIGN regulation;
Support CFPB exercise of larger participant authority to oversee fintech companies;
Support fair distribution of Regulation E error resolution responsibilities;
Support clear regulatory framework for digital assets to encourage responsible innovation and permit credit union participation;
Support CDFI Fund transparency on certification changes;
Support streamlining and modernization of CDFI Fund certification process;
Support Congressional oversight of SBAs Affiliation and Small Business Lending Company proposed rules;
Support tax deduction for mortgage insurance premiums;
Support modification or removal of the credit union member business lending cap;
FHFA should allow GSEs to purchase non-conforming loans from CDFIs;
Support alternative credit scoring models;
Oppose development of a CBDC;
Support prevention of an NFIP lapse;
Support improving veterans access to capital by exempting credit unions business loans to veterans from the credit union member business lending cap;
Support expanding the definition of Community Financial Institutions (CFIs) in the Federal Home Loan Bank Act (FHLB Act) to include credit unions and Treasury-certified non-depository community development financial institutions;
Oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation;
Support parity for credit unions related to stablecoin regulation;
Treasury should address the demand for coins to help consumers who rely on cash transactions;
Support addressing appraisal bias and modernize the appraisal process for consistency;
Support for forced arbitration - studies show consumers benefit more often from arbitration than litigation;
Support easing requirements for de novo credit unions;
Support providing flexibility for credit unions to issue subordinated debt;
Support H.R. 5189, the Member Business Loan Expansion Act;
Support the Federal Home Loan Banks' Mission Implementation Act (H.R. 3323, S.1684);
Support H.R. 4773, the Consumer Financial Protection Commission Act;
Oppose legislation granting NCUA third-party vendor examination authority (H.R. 7022, S. 4698);
Oppose Credit Card Competition Act (H.R. 8874, S. 4674);
Support SAFE Banking Act (H.R. 1996, S. 910);
Support Central Liquidity Facility Enhancement Act (H.R. 3958, S. 5183);
Support Credit Union Board Modernization Act (H.R. 6889, S. 4325);
Support Expanding Financial Access for Underserved Communities Act (H.R. 7003, S. 4879);
Support CDFI Bond Guarantee Program Improvement Act (H.R. 7733, S. 3441);
Support Title III, Subtitle C of H.R. 2543 - Promoting and Advancing Communities of Color Through Inclusive Lending;
Support S. 3590, the Middle Class Mortgage Insurance Premium Act;
Oppose inclusion of the Credit Card Competition Act (H.R. 8874, S. 4674) or NCUA third-party vendor examination authority (H.R. 7022, S. 4698) in the FY 2023 NDAA;
Support H.R. 5912, the Close the ILC Loophole Act;
Support S. 762, the Expanding Access to Lending Options Act;
Oppose Senate NDAA amendments 6201 and 6174 on credit card interchange;
Support S. 4165, the CDFI Crisis Fund Act;
Oppose H.R. 4277, the Overdraft Protection Act;
Oppose FDCPA changes that improperly burden creditors in H.R. 6814, the Small Business Fair Debt Collection Protection Act;
Oppose inclusion of bank lease provision in FY 2023 NDAA;
Oppose H.R. 8152, the American Data Privacy and Protection Act;
Support H.R. 5911, the Fair Hiring in Banking Act;
Support H.R. 4590, the Promoting New and Diverse Depository Institutions Act;
Oppose H.R. 8485, the Expanding Access to Credit through Consumer-Permissioned Data Act;
Support the Small LENDER Act (H.R. 6732, S. 4004);
Support H.R. 7628, the Improve the SBA Act;
Support the SECURE Notarization Act (H.R. 3962, S. 1625);
Support the TAILOR Act (H.R. 766, S. 3745);
Support the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act (H.R. 7412, S.4522);
Support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act;
Oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act;
Support S. 5189, the Close the Shadow Banking Loophole Act;
Support for Advancing Technologies to Support Inclusion Act discussion draft;
Support for Creation of Diverse and Mission-Driven Community Financial Institutions Act discussion draft;
Comments to SBA on RIN 3245-AH87 expressing concern about interaction between Affiliation and Small Business Lending Company proposed rules;
Request for extension of temporary NCUA relief on loan participation and eligible obligation regulations due to the COVID-19 pandemic;
Request for clarification of CFPB authority and intention for auto loan data collection;
Comments to Treasury Dept on Docket No. 2022-21524 requesting streamlined applications for federal community investment programs;
Comments to CDFI Fund on Docket No. 2022-22767 requesting modification of proposed pre-approved Target Market assessment methodologies;
Comments to EPA on Docket ID No. EPA-HQ-OA-2022-0859 opposing establishment of single national green bank and supporting credit union inclusion as indirect recipients of Greenhouse Gas Reduction Fund disbursements;
Comments to NCUA on RIN: 3133-AF43 supporting the elimination of the maximum maturity requirement for subordinated debt;
Comments to CDFI Fund on Docket No. 2022-24082 opposing changes to CDFI certification requirements;
Comments to NCUA on Docket No. NCUA-2022-0132 opposing overly complex member expulsion process;
Support delay of GSEs credit fee caps effective date;
Comments to CFPB on Docket No. CFPB-2022-0059 supporting additional flexibility in the Qualified Mortgage rule;
Comments to FTC on R111004 opposing data privacy rulemaking absent comprehensive federal legislation;
Support elimination of in-person quorum requirement for credit union annual meetings;
Comments to CISA on Docket ID: CISA-2022-0010 supporting simplification of cyber incident reporting requirements;
Support inclusion of 501(c)(19) veterans organizations as qualified charit[ies] in NCUA regulations;
Comments to Treasury Department on Document No. 2022-20279 supporting application of Bank Secrecy Act and anti-money laundering regulations to digital assets and supporting interagency coordination to ensure credit union inclusion in digital asset regulations;
Comments to FHFA on Federal Home Loan Bank System review supporting capital requirements for System members and supporting alignment of tangible capital definitions among regulators;
Comments to FHFA on Fintech in Housing Finance supporting interagency coordination and caution in integration of non-depository fintech lenders;
Comments to NCUA on RIN 3064-ZA33 supporting flexibility in updated commercial real estate loan accommodations policy statement;
Oppose increases to NCUAs 2023-2024 budget and support increased budget transparency;
Oppose expansion of Regulation E liability;

17. House(s) of Congress and Federal agencies Check if None

Natl Credit Union Administration (NCUA), Small Business Administration (SBA), Defense - Dept of (DOD), Federal Reserve System, Treasury - Dept of, Securities & Exchange Commission (SEC), Housing & Urban Development - Dept of (HUD), Government Accountability Office (GAO), White House Office, Federal Housing Finance Agency (FHFA), Consumer Financial Protection Bureau (CFPB), Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Federal Communications Commission (FCC), Labor - Dept of (DOL), Veterans Affairs - Dept of (VA), Environmental Protection Agency (EPA)

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

​

LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code FIN

16. Specific lobbying issues

Protect the credit union tax exemption;
Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members;
Support regulatory relief for credit unions;
Provide guidance or rulemakings rather than rule through enforcement;
Support increase in funding for CDFI Fund, MDIs, and the CDRLF;
Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight;
Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies;
Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members;
Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper;
Support extending GLBA like data security measures to retailers;
Support recognizing GLBA compliance in any privacy legislation;
Oppose SBA direct lending authority;
Support improvements to ease the process for forgiveness of PPP loans to small businesses;
Oppose limits on fee income for credit unions including courtesy pay;
Support CFPB study of overdraft programs to determine the value to consumers;
Support limiting burdens of HMDA rule on credit unions;
CFPB should remove unnecessary and unused data points related to HMDA reporting;
Support permanently increasing reporting thresholds for open- and closed-end loans;
Prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products;
CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate;
CFPB should engage in interagency coordination on Section 1033 consumer access to financial records rulemaking;
Oppose CFPBs characterization of regulated and disclosed financial services fees as junk fees;
CFPB should explore streamlining required fee disclosures;
CFPB should clarify UDAAP authority;
CFPB should respect GLBAs data security regulatory structure;
CFPB should limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09);
Improve examination coordination between CFPB and NCUA;
Support permanent adoption of CFPBs expired temporary relief of E-SIGN regulation;
Support CFPB exercise of larger participant authority to oversee fintech companies;
Support fair distribution of Regulation E error resolution responsibilities;
Support clear regulatory framework for digital assets to encourage responsible innovation and permit credit union participation;
Support CDFI Fund transparency on certification changes;
Support streamlining and modernization of CDFI Fund certification process;
Support Congressional oversight of SBAs Affiliation and Small Business Lending Company proposed rules;
Support tax deduction for mortgage insurance premiums;
Support modification or removal of the credit union member business lending cap;
FHFA should allow GSEs to purchase non-conforming loans from CDFIs;
Support alternative credit scoring models;
Oppose development of a CBDC;
Support prevention of an NFIP lapse;
Support improving veterans access to capital by exempting credit unions business loans to veterans from the credit union member business lending cap;
Support expanding the definition of Community Financial Institutions (CFIs) in the Federal Home Loan Bank Act (FHLB Act) to include credit unions and Treasury-certified non-depository community development financial institutions;
Oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation;
Support parity for credit unions related to stablecoin regulation;
Treasury should address the demand for coins to help consumers who rely on cash transactions;
Support addressing appraisal bias and modernize the appraisal process for consistency;
Support for forced arbitration - studies show consumers benefit more often from arbitration than litigation;
Support easing requirements for de novo credit unions;
Support providing flexibility for credit unions to issue subordinated debt;
Support H.R. 5189, the Member Business Loan Expansion Act;
Support the Federal Home Loan Banks' Mission Implementation Act (H.R. 3323, S.1684);
Support H.R. 4773, the Consumer Financial Protection Commission Act;
Oppose legislation granting NCUA third-party vendor examination authority (H.R. 7022, S. 4698);
Oppose Credit Card Competition Act (H.R. 8874, S. 4674);
Support SAFE Banking Act (H.R. 1996, S. 910);
Support Central Liquidity Facility Enhancement Act (H.R. 3958, S. 5183);
Support Credit Union Board Modernization Act (H.R. 6889, S. 4325);
Support Expanding Financial Access for Underserved Communities Act (H.R. 7003, S. 4879);
Support CDFI Bond Guarantee Program Improvement Act (H.R. 7733, S. 3441);
Support Title III, Subtitle C of H.R. 2543 - Promoting and Advancing Communities of Color Through Inclusive Lending;
Support S. 3590, the Middle Class Mortgage Insurance Premium Act;
Oppose inclusion of the Credit Card Competition Act (H.R. 8874, S. 4674) or NCUA third-party vendor examination authority (H.R. 7022, S. 4698) in the FY 2023 NDAA;
Support H.R. 5912, the Close the ILC Loophole Act;
Support S. 762, the Expanding Access to Lending Options Act;
Oppose Senate NDAA amendments 6201 and 6174 on credit card interchange;
Support S. 4165, the CDFI Crisis Fund Act;
Oppose H.R. 4277, the Overdraft Protection Act;
Oppose FDCPA changes that improperly burden creditors in H.R. 6814, the Small Business Fair Debt Collection Protection Act;
Oppose inclusion of bank lease provision in FY 2023 NDAA;
Oppose H.R. 8152, the American Data Privacy and Protection Act;
Support H.R. 5911, the Fair Hiring in Banking Act;
Support H.R. 4590, the Promoting New and Diverse Depository Institutions Act;
Oppose H.R. 8485, the Expanding Access to Credit through Consumer-Permissioned Data Act;
Support the Small LENDER Act (H.R. 6732, S. 4004);
Support H.R. 7628, the Improve the SBA Act;
Support the SECURE Notarization Act (H.R. 3962, S. 1625);
Support the TAILOR Act (H.R. 766, S. 3745);
Support the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act (H.R. 7412, S.4522);
Support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act;
Oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act;
Support S. 5189, the Close the Shadow Banking Loophole Act;
Support for Advancing Technologies to Support Inclusion Act discussion draft;
Support for Creation of Diverse and Mission-Driven Community Financial Institutions Act discussion draft;
Comments to SBA on RIN 3245-AH87 expressing concern about interaction between Affiliation and Small Business Lending Company proposed rules;
Request for extension of temporary NCUA relief on loan participation and eligible obligation regulations due to the COVID-19 pandemic;
Request for clarification of CFPB authority and intention for auto loan data collection;
Comments to Treasury Dept on Docket No. 2022-21524 requesting streamlined applications for federal community investment programs;
Comments to CDFI Fund on Docket No. 2022-22767 requesting modification of proposed pre-approved Target Market assessment methodologies;
Comments to EPA on Docket ID No. EPA-HQ-OA-2022-0859 opposing establishment of single national green bank and supporting credit union inclusion as indirect recipients of Greenhouse Gas Reduction Fund disbursements;
Comments to NCUA on RIN: 3133-AF43 supporting the elimination of the maximum maturity requirement for subordinated debt;
Comments to CDFI Fund on Docket No. 2022-24082 opposing changes to CDFI certification requirements;
Comments to NCUA on Docket No. NCUA-2022-0132 opposing overly complex member expulsion process;
Support delay of GSEs credit fee caps effective date;
Comments to CFPB on Docket No. CFPB-2022-0059 supporting additional flexibility in the Qualified Mortgage rule;
Comments to FTC on R111004 opposing data privacy rulemaking absent comprehensive federal legislation;
Support elimination of in-person quorum requirement for credit union annual meetings;
Comments to CISA on Docket ID: CISA-2022-0010 supporting simplification of cyber incident reporting requirements;
Support inclusion of 501(c)(19) veterans organizations as qualified charit[ies] in NCUA regulations;
Comments to Treasury Department on Document No. 2022-20279 supporting application of Bank Secrecy Act and anti-money laundering regulations to digital assets and supporting interagency coordination to ensure credit union inclusion in digital asset regulations;
Comments to FHFA on Federal Home Loan Bank System review supporting capital requirements for System members and supporting alignment of tangible capital definitions among regulators;
Comments to FHFA on Fintech in Housing Finance supporting interagency coordination and caution in integration of non-depository fintech lenders;
Comments to NCUA on RIN 3064-ZA33 supporting flexibility in updated commercial real estate loan accommodations policy statement;
Oppose increases to NCUAs 2023-2024 budget and support increased budget transparency;
Oppose expansion of Regulation E liability;

17. House(s) of Congress and Federal agencies Check if None

Natl Credit Union Administration (NCUA), Small Business Administration (SBA), Defense - Dept of (DOD), Federal Reserve System, Treasury - Dept of, Securities & Exchange Commission (SEC), Housing & Urban Development - Dept of (HUD), Government Accountability Office (GAO), White House Office, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Federal Housing Finance Agency (FHFA), Consumer Financial Protection Bureau (CFPB), Federal Communications Commission (FCC), Labor - Dept of (DOL), Veterans Affairs - Dept of (VA), Environmental Protection Agency (EPA)

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

​

LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code TAX

16. Specific lobbying issues

Protect the credit union tax exemption

17. House(s) of Congress and Federal agencies Check if None

Internal Revenue Service (IRS), Natl Credit Union Administration (NCUA), Treasury - Dept of, White House Office, U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Federal Trade Commission (FTC), Federal Reserve System

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

​

Information Update Page - Complete ONLY where registration information has changed.

20. Client new address

21. Client new principal place of business (if different than line 20)

22. New General description of client’s business or activities

LOBBYIST UPDATE

23. Name of each previously reported individual who is no longer expected to act as a lobbyist for the client

ISSUE UPDATE

24. General lobbying issue that no longer pertains

AFFILIATED ORGANIZATIONS

25. Add the following affiliated organization(s)

Internet Address: https://www.nafcu.org/boardofdirectors

26. Name of each previously reported organization that is no longer affiliated with the registrant or client

FOREIGN ENTITIES

27. Add the following foreign entities:

28. Name of each previously reported foreign entity that no longer owns, or controls, or is affiliated with the registrant, client or affiliated organization

CONVICTIONS DISCLOSURE

29. Have any of the lobbyists listed on this report been convicted in a Federal or State Court of an offense involving bribery, extortion, embezzlement, an illegal kickback, tax evasion, fraud, a conflict of interest, making a false statement, perjury, or money laundering?
No Yes