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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
Address1 | 901 Community Drive |
Address2 | |
City | Springfield |
State | IL |
Zip Code | 62703 |
Country | USA |
3. Principal place of business (if different than line 2)
City | |
State | |
Zip Code | |
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5. Senate ID# 400531588-12
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6. House ID# 411650000
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TYPE OF REPORT | 8. Year | 2014 |
Q1 (1/1 - 3/31) | Q2 (4/1 - 6/30) | Q3 (7/1 - 9/30) | Q4 (10/1 - 12/31) |
9. Check if this filing amends a previously filed version of this report
10. Check if this is a Termination Report | Termination Date | |
11. No Lobbying Issue Activity |
INCOME OR EXPENSES - YOU MUST complete either Line 12 or Line 13 | |||||||||
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12. Lobbying | 13. Organizations | ||||||||
INCOME relating to lobbying activities for this reporting period was: | EXPENSE relating to lobbying activities for this reporting period were: | ||||||||
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Provide a good faith estimate, rounded to the nearest $10,000, of all lobbying related income for the client (including all payments to the registrant by any other entity for lobbying activities on behalf of the client). | 14. REPORTING Check box to indicate expense accounting method. See instructions for description of options. | ||||||||
Method A.
Reporting amounts using LDA definitions only
Method B. Reporting amounts under section 6033(b)(8) of the Internal Revenue Code Method C. Reporting amounts under section 162(e) of the Internal Revenue Code |
Signature | Digitally Signed By: David G. Schroeder Vice President Federal Governmental Relations |
Date | 10/19/2014 |
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
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 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)
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
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Treasury - Dept of, Federal Housing Finance Board (FHFB), Federal Deposit Insurance Commission (FDIC), Federal Reserve System, Office of the Comptroller of the Currency (OCC)
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
David |
Schroeder |
|
|
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
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 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)
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
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Treasury - Dept of, Federal Housing Finance Board (FHFB), Federal Deposit Insurance Commission (FDIC), Federal Reserve System, Office of the Comptroller of the Currency (OCC)
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
David |
Schroeder |
|
|
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 AGR
16. Specific lobbying issues
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)
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Treasury - Dept of, Federal Housing Finance Board (FHFB)
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
David |
Schroeder |
|
|
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 CSP
16. Specific lobbying issues
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
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 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)
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Treasury - Dept of, Federal Housing Finance Board (FHFB)
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
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Schroeder |
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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 SMB
16. Specific lobbying issues
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 (Senate)
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
David |
Schroeder |
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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
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 (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)
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
David |
Schroeder |
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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.
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LOBBYIST UPDATE
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ISSUE UPDATE
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AFFILIATED ORGANIZATIONS
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FOREIGN ENTITIES
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28. Name of each previously reported foreign entity that no longer owns, or controls, or is affiliated with the registrant, client or affiliated organization
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