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; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; streamline regulations to allow credit unions to better serve members and cut compliance costs; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time - CRT transactions should be expanded and CSP and single security retained - FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; reforms to the TCPA Act to ensure that credit unions are able to contact their members, S.151; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws(RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; FidelityBonds(RIN3133-AE87) - NCUA should re-evaluate the additional oversight requirements to achieve an operationally efficient and cost-effective solution. NCUA should maintain the current regulation requiring annual review by a federal credit union(FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal.. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; move to confirm NCUA nominees Hood and Harper as soon as possible; move to confirm FHFA Director nominee, Calabria as soon as possible; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; Technical issues with HMDA Platform - CFPB and NCUA should interpret good faith compliance under Regulation C to excuse highly disruptive technical problems that are attributable to the design and programming of the HMDA Platform and clarify how they intend to evaluate errors caused by technical problems on the HMDA Platform that are not the fault of credit unions; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans(RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases.

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

Natl Credit Union Administration (NCUA), Small Business Administration (SBA), Defense - Dept of (DOD), Homeland Security - Dept of (DHS), Federal Reserve System, Treasury - Dept of, Federal Deposit Insurance Corporation (FDIC), Securities & Exchange Commission (SEC), Housing & Urban Development - Dept of (HUD), Office of the Comptroller of the Currency (OCC), 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), Commodity Futures Trading Commission (CFTC), Justice - Dept of (DOJ), U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Federal Communications Commission (FCC), Labor - Dept of (DOL)

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; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; streamline regulations to allow credit unions to better serve members and cut compliance costs; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time - CRT transactions should be expanded and CSP and single security retained - FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; reforms to the TCPA Act to ensure that credit unions are able to contact their members, S.151; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws(RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; FidelityBonds(RIN3133-AE87) - NCUA should re-evaluate the additional oversight requirements to achieve an operationally efficient and cost-effective solution. NCUA should maintain the current regulation requiring annual review by a federal credit union(FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal.. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; move to confirm NCUA nominees Hood and Harper as soon as possible; move to confirm FHFA Director nominee, Calabria as soon as possible; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; Technical issues with HMDA Platform - CFPB and NCUA should interpret good faith compliance under Regulation C to excuse highly disruptive technical problems that are attributable to the design and programming of the HMDA Platform and clarify how they intend to evaluate errors caused by technical problems on the HMDA Platform that are not the fault of credit unions; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans(RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases.

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

Natl Credit Union Administration (NCUA), Small Business Administration (SBA), Defense - Dept of (DOD), Homeland Security - Dept of (DHS), Federal Reserve System, Treasury - Dept of, Federal Deposit Insurance Corporation (FDIC), Securities & Exchange Commission (SEC), Housing & Urban Development - Dept of (HUD), Office of the Comptroller of the Currency (OCC), Government Accountability Office (GAO), White House Office, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Commodity Futures Trading Commission (CFTC), Justice - Dept of (DOJ), U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Federal Housing Finance Agency (FHFA), Consumer Financial Protection Bureau (CFPB), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Federal Communications Commission (FCC), Labor - Dept of (DOL)

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, Office of Management & Budget (OMB)

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