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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 |
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| City | Springfield |
State | IL |
Zip Code | 62703-5184 |
Country | USA |
3. Principal place of business (if different than line 2)
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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 | 2020 |
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 |
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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. | ||||||||
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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 |
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| Signature | Digitally Signed By: David G. Schroeder |
Date | 10/16/2020 6:46:57 PM |
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 2020 Federal Policy Priorities -
Support The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity
Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155)
Support Additional Meaningful Regulatory Relief for Community Banks
Oppose Credit Unions Expanded Powers
Close the Industrial Loan Company (ILC) Regulatory Loophole
Oppose Farm Credit Systems Expanded Powers
Support the Federal Reserves Role in Payments System Improvement
Support Modernizing the Community Reinvestment Act (CRA)
Modify the FDICs Brokered Deposit Rule
Support Safe Harbor for Banking Cannabis-Related Businesses
Support De Novo Community Bank Formation, the Dual Banking System and Charter Choice
Support Sound Principles for GSE Reform
Support the Federal Home Loan Banks
Support Agriculture and Rural America
Support Enhanced Data, Cyber and Payment Card Security (Data Security)
Support Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks
Support the Community Bank Positions on Emerging Issues
OCCs Special Purpose Fintech National Bank (SPNBs) Fintech Charters
FASBs Current Expected Credit Loss Model
CFPBs Customer Data Sharing
CFPBs Small-Dollar Consumer Lending
CFPB's Small Business Data Collection
Federal Reserves Modernize Reg CC
Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts
(House, Senate, CFPB, OCC, FDIC, Federal Reserve, FHFA)
Legislation and Regulation -
S. 4117 - Paycheck Protection Small Business Forgiveness Act (All Sections) Regarding Paycheck Protection Program (PPP) loans of $150,000 and under qualifying for forgiveness with one-page application (Senate)
H.R. 7777 - Paycheck Protection Small Business Forgiveness Act (All Sections) Regarding Paycheck Protection Program (PPP) loans of $150,000 and under provided automatic forgiveness (House)
Closing the Industrial Loan Company (ILC) loophole - discussion draft of legislation (House)
Closing the Industrial Loan Company (ILC) loophole - Wirecard AG and Wirecard Bank in Germany and similarities with U.S. ILCs and their holding companies (House)
Community Bank top priorities for pandemic relief measures -
1) Cosponsor legislation in the Senate and House (S. 4117 and H.R. 7777), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less;
2) Allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses. (S. 3612/H.R. 6821);
3) Support local regions by raising the current bank-qualified municipal bond annual issuance limit to $50 million from $10 million to expedite low-cost funding for local projects;
4) Enact bank capital and accounting relief measures to support borrowers and lenders facing historically challenging circumstances by extending Troubled Debt Restructuring (TDR), suspending the Current Expected Credit Loss (CECL) requirements, and making the 8% Community Bank Leverage Ratio (CBLR) permanent for institutions of $10 billion or less in assets;
5) Create capacity for additional lending by requiring SBA to purchase PPP loan at par;
6) Create a liability safe harbor for businesses from COVID-19-related lawsuits;
7) Support rural America by allowing interest on loans secured by agricultural real estate or primary residences in rural communities to be tax-exempt (ECORA, S. 1641/H.R. 1872), providing direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhance USDA guaranteed lending programs;
8) Expand the Employee Retention Tax Credit (ERTC) created by the CARES Act (H.R. 6776);
9) Enact an Industrial Loan Company moratorium of at least three years on the FDICs approval of deposit insurance applications. (A three-year moratorium was included in the Dodd-Frank Act as an appropriate response to a highly uncertain economic environment);
10) Extend the QM patch to January 2022 to help avoid additional disruption to the housing market. (House and Senate)
Second Initiative - Community Bank top priorities for pandemic relief measures -
1) Support Sen. Cramers legislation (S. 4117), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less-allowing business owners to focus on their businesses and the safety of their employees and customers (protections against fraud and misrepresentation still apply).
2) Support Sen. Kings legislation (S. 4171), which would require Treasury or SBA (not a third-party) to create an easy-to-use online loan forgiveness calculator to help clear up what is a very confusing and complex application process. This would ensure borrowers and lenders protection and accuracy.
3) Support Rep. Houlahans legislation (H.R. 7777), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less-allowing business owners to focus on their businesses and the safety of their employees and customers (protections against fraud and misrepresentation still apply).
4) Support Rep. Wagners legislation (H.R. 7413), which would require Treasury or SBA (not a third-party) to create an easy-to-use online loan forgiveness calculator to help clear up what is a very confusing and complex application process. This would ensure borrowers and lenders protection and accuracy.
5) Create capacity for additional lending by requiring SBA to purchase PPP loans at par (minus the amount that has been forgiven).
6) Ensure PPP loans are not included in regulatory asset threshold calculations. If PPP lending causes our assets to exceed certain thresholds, additional regulations and supervision are triggered, causing many community banks to face costly, burdensome and unintended consequences.
7) Support Sen. Cornyns legislation (S. 3612), which would allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses, as they ordinarily would. Without this, the value of a PPP loan is effectively reduced and tax preparation is unnecessarily cumbersome.
8) Support Rep. Holdings legislation (H.R. 6821), which would allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses, as they ordinarily would. Without this, the value of a PPP loan is effectively reduced and tax preparation is unnecessarily cumbersome.
9) Enact bank capital and accounting relief measures to support borrowers and lenders facing historically challenging circumstances by extending TDR, suspending CECL and making the 8% CBLR permanent for institutions of $10 billion or less in assets. Banks strong capitalization at the beginning of the crisis means that capital and accounting could be implemented without compromising safety and soundness.
10) Create a liability safe harbor for businesses from COVID-19-related lawsuits. Community banks and small businesses have every incentive to ensure the personal safety of their employees and customers. Fear of opportunistic class actions or other suits will inhibit the restoration of economic activity.
11) Support rural America by passing Rep. Watkinss ECORA Act (H.R. 1872), which exempts interest on most agricultural loans from taxable income (lowering interest rates for farmers, ranchers and rural homeowners), provides direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhances USDA guaranteed lending programs. (House, Senate)
FHFA/Fannie/Freddie .50% residential mortgage guarantee fee increase with a September 1, 2020 implementation date (FHFA, Federal Reserve, OCC, House, Senate)
S. 2939 - Eliminating Corporate Shadow Banking Act of 2019 (all Sections) Regarding closing the Industrial Loan Company loophole - consolidated holding company supervision by the Federal Reserve (Senate)
Revised FDIC Guidelines for Appeals of Material Supervisory Determinations (FDIC)
Letters -
Comment Letter to the Federal Deposit Insurance Corporation (FDIC) regarding: Proposed Rule - Parent Companies of Industrial Banks and Industrial Loan Companies; RIN 3064-AF31 (FDIC, House, Federal Reserve)
Addendum to Comment Letter to the Federal Deposit Insurance Corporation (FDIC) regarding: Proposed Rule - Parent Companies of Industrial Banks and Industrial Loan Companies; RIN 3064-AF31 (FDIC, House, Federal Reserve)
Comment Letter to the National Credit Union Administration (NCUA) regarding: Subordinated Debt; Proposed Rule RIN 3133-AF08 (NCUA)
Comment Letter to the Consumer Financial Protection Bureau (CFPB) regarding: Request for Information on Equal Credit Opportunity and Regulation B; Docket No CFPB-2020-0026 (CFPB)
Action Alerts -
Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate)
Action Alert regarding FHFA/Fannie/Freddie .50% residential mortgage guarantee fee increase with a September 1, 2020 implementation date (House, Senate)
#2 Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate)
Miscellaneous -
OCC proposal to issue payments charters (OCC)
Beneficial ownership reporting regulatory relief (with FinCEN - not a community bank responsibility) (House)
Postal Service financial services [banking] pilot program (House)
Community Reinvestment Act (CRA) modernization (joint rulemaking) (House)
Payments System Improvements (Federal Reserve FedNow Service) (House)
FinCEN breach of information on Suspicious Activity Reports (SARs) (FDIC)
Expiration of time to receive, and delivery of, Economic Impact Payments (EIPs) (House, Senate)
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Consumer Financial Protection Bureau (CFPB), Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Housing Finance Agency (FHFA), Natl Credit Union Administration (NCUA)
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 2020 Federal Policy Priorities -
Support The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity
Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155)
Support Additional Meaningful Regulatory Relief for Community Banks
Oppose Credit Unions Expanded Powers
Close the Industrial Loan Company (ILC) Regulatory Loophole
Oppose Farm Credit Systems Expanded Powers
Support the Federal Reserves Role in Payments System Improvement
Support Modernizing the Community Reinvestment Act (CRA)
Modify the FDICs Brokered Deposit Rule
Support Safe Harbor for Banking Cannabis-Related Businesses
Support De Novo Community Bank Formation, the Dual Banking System and Charter Choice
Support Sound Principles for GSE Reform
Support the Federal Home Loan Banks
Support Agriculture and Rural America
Support Enhanced Data, Cyber and Payment Card Security (Data Security)
Support Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks
Support the Community Bank Positions on Emerging Issues
OCCs Special Purpose Fintech National Bank (SPNBs) Fintech Charters
FASBs Current Expected Credit Loss Model
CFPBs Customer Data Sharing
CFPBs Small-Dollar Consumer Lending
CFPB's Small Business Data Collection
Federal Reserves Modernize Reg CC
Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts
(House, Senate, CFPB, OCC, FDIC, Federal Reserve, FHFA)
Legislation and Regulation -
S. 4117 - Paycheck Protection Small Business Forgiveness Act (All Sections) Regarding Paycheck Protection Program (PPP) loans of $150,000 and under qualifying for forgiveness with one-page application (Senate)
H.R. 7777 - Paycheck Protection Small Business Forgiveness Act (All Sections) Regarding Paycheck Protection Program (PPP) loans of $150,000 and under provided automatic forgiveness (House)
Closing the Industrial Loan Company (ILC) loophole - discussion draft of legislation (House)
Closing the Industrial Loan Company (ILC) loophole - Wirecard AG and Wirecard Bank in Germany and similarities with U.S. ILCs and their holding companies (House)
Community Bank top priorities for pandemic relief measures -
1) Cosponsor legislation in the Senate and House (S. 4117 and H.R. 7777), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less;
2) Allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses. (S. 3612/H.R. 6821);
3) Support local regions by raising the current bank-qualified municipal bond annual issuance limit to $50 million from $10 million to expedite low-cost funding for local projects;
4) Enact bank capital and accounting relief measures to support borrowers and lenders facing historically challenging circumstances by extending Troubled Debt Restructuring (TDR), suspending the Current Expected Credit Loss (CECL) requirements, and making the 8% Community Bank Leverage Ratio (CBLR) permanent for institutions of $10 billion or less in assets;
5) Create capacity for additional lending by requiring SBA to purchase PPP loan at par;
6) Create a liability safe harbor for businesses from COVID-19-related lawsuits;
7) Support rural America by allowing interest on loans secured by agricultural real estate or primary residences in rural communities to be tax-exempt (ECORA, S. 1641/H.R. 1872), providing direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhance USDA guaranteed lending programs;
8) Expand the Employee Retention Tax Credit (ERTC) created by the CARES Act (H.R. 6776);
9) Enact an Industrial Loan Company moratorium of at least three years on the FDICs approval of deposit insurance applications. (A three-year moratorium was included in the Dodd-Frank Act as an appropriate response to a highly uncertain economic environment);
10) Extend the QM patch to January 2022 to help avoid additional disruption to the housing market. (House and Senate)
Second Initiative - Community Bank top priorities for pandemic relief measures -
1) Support Sen. Cramers legislation (S. 4117), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less-allowing business owners to focus on their businesses and the safety of their employees and customers (protections against fraud and misrepresentation still apply).
2) Support Sen. Kings legislation (S. 4171), which would require Treasury or SBA (not a third-party) to create an easy-to-use online loan forgiveness calculator to help clear up what is a very confusing and complex application process. This would ensure borrowers and lenders protection and accuracy.
3) Support Rep. Houlahans legislation (H.R. 7777), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less-allowing business owners to focus on their businesses and the safety of their employees and customers (protections against fraud and misrepresentation still apply).
4) Support Rep. Wagners legislation (H.R. 7413), which would require Treasury or SBA (not a third-party) to create an easy-to-use online loan forgiveness calculator to help clear up what is a very confusing and complex application process. This would ensure borrowers and lenders protection and accuracy.
5) Create capacity for additional lending by requiring SBA to purchase PPP loans at par (minus the amount that has been forgiven).
6) Ensure PPP loans are not included in regulatory asset threshold calculations. If PPP lending causes our assets to exceed certain thresholds, additional regulations and supervision are triggered, causing many community banks to face costly, burdensome and unintended consequences.
7) Support Sen. Cornyns legislation (S. 3612), which would allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses, as they ordinarily would. Without this, the value of a PPP loan is effectively reduced and tax preparation is unnecessarily cumbersome.
8) Support Rep. Holdings legislation (H.R. 6821), which would allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses, as they ordinarily would. Without this, the value of a PPP loan is effectively reduced and tax preparation is unnecessarily cumbersome.
9) Enact bank capital and accounting relief measures to support borrowers and lenders facing historically challenging circumstances by extending TDR, suspending CECL and making the 8% CBLR permanent for institutions of $10 billion or less in assets. Banks strong capitalization at the beginning of the crisis means that capital and accounting could be implemented without compromising safety and soundness.
10) Create a liability safe harbor for businesses from COVID-19-related lawsuits. Community banks and small businesses have every incentive to ensure the personal safety of their employees and customers. Fear of opportunistic class actions or other suits will inhibit the restoration of economic activity.
11) Support rural America by passing Rep. Watkinss ECORA Act (H.R. 1872), which exempts interest on most agricultural loans from taxable income (lowering interest rates for farmers, ranchers and rural homeowners), provides direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhances USDA guaranteed lending programs. (House, Senate)
FHFA/Fannie/Freddie .50% residential mortgage guarantee fee increase with a September 1, 2020 implementation date (FHFA, Federal Reserve, OCC, House, Senate)
S. 2939 - Eliminating Corporate Shadow Banking Act of 2019 (all Sections) Regarding closing the Industrial Loan Company loophole - consolidated holding company supervision by the Federal Reserve (Senate)
Revised FDIC Guidelines for Appeals of Material Supervisory Determinations (FDIC)
Letters -
Comment Letter to the Federal Deposit Insurance Corporation (FDIC) regarding: Proposed Rule - Parent Companies of Industrial Banks and Industrial Loan Companies; RIN 3064-AF31 (FDIC, House, Federal Reserve)
Addendum to Comment Letter to the Federal Deposit Insurance Corporation (FDIC) regarding: Proposed Rule - Parent Companies of Industrial Banks and Industrial Loan Companies; RIN 3064-AF31 (FDIC, House, Federal Reserve)
Comment Letter to the National Credit Union Administration (NCUA) regarding: Subordinated Debt; Proposed Rule RIN 3133-AF08 (NCUA)
Comment Letter to the Consumer Financial Protection Bureau (CFPB) regarding: Request for Information on Equal Credit Opportunity and Regulation B; Docket No CFPB-2020-0026 (CFPB)
Action Alerts -
Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate)
Action Alert regarding FHFA/Fannie/Freddie .50% residential mortgage guarantee fee increase with a September 1, 2020 implementation date (House, Senate)
#2 Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate)
Miscellaneous -
OCC proposal to issue payments charters (OCC)
Beneficial ownership reporting regulatory relief (with FinCEN - not a community bank responsibility) (House)
Postal Service financial services [banking] pilot program (House)
Community Reinvestment Act (CRA) modernization (joint rulemaking) (House)
Payments System Improvements (Federal Reserve FedNow Service) (House)
FinCEN breach of information on Suspicious Activity Reports (SARs) (FDIC)
Expiration of time to receive, and delivery of, Economic Impact Payments (EIPs) (House, Senate)
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Consumer Financial Protection Bureau (CFPB), Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Housing Finance Agency (FHFA), Natl Credit Union Administration (NCUA)
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 2020 Federal Policy Priorities -
Support The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity
Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155)
Support Additional Meaningful Regulatory Relief for Community Banks
Oppose Credit Unions Expanded Powers
Oppose Farm Credit Systems Expanded Powers
Support the Federal Reserves Role in Payments System Improvement
Support Modernizing the Community Reinvestment Act (CRA)
Support Safe Harbor for Banking Cannabis-Related Businesses
Support Sound Principles for GSE Reform
Support the Federal Home Loan Banks
Support Agriculture and Rural America
Support Enhanced Data, Cyber and Payment Card Security (Data Security)
Support the Community Bank Positions on Emerging Issues
CFPBs Customer Data Sharing
CFPB's Small Business Data Collection
Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts
(House, Senate, CFPB, OCC, FDIC, Federal Reserve, FHFA)
Legislation and Regulation -
S. 4117 - Paycheck Protection Small Business Forgiveness Act (All Sections) Regarding Paycheck Protection Program (PPP) loans of $150,000 and under qualifying for forgiveness with one-page application (Senate)
H.R. 7777 - Paycheck Protection Small Business Forgiveness Act (All Sections) Regarding Paycheck Protection Program (PPP) loans of $150,000 and under provided automatic forgiveness (House)
Community Bank top priorities for pandemic relief measures -
1) Cosponsor legislation in the Senate and House (S. 4117 and H.R. 7777), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less;
2) Allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses. (S. 3612/H.R. 6821);
3) Support local regions by raising the current bank-qualified municipal bond annual issuance limit to $50 million from $10 million to expedite low-cost funding for local projects;
4) Enact bank capital and accounting relief measures to support borrowers and lenders facing historically challenging circumstances by extending Troubled Debt Restructuring (TDR), suspending the Current Expected Credit Loss (CECL) requirements, and making the 8% Community Bank Leverage Ratio (CBLR) permanent for institutions of $10 billion or less in assets;
5) Create capacity for additional lending by requiring SBA to purchase PPP loan at par;
6) Create a liability safe harbor for businesses from COVID-19-related lawsuits;
7) Support rural America by allowing interest on loans secured by agricultural real estate or primary residences in rural communities to be tax-exempt (ECORA, S. 1641/H.R. 1872), providing direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhance USDA guaranteed lending programs;
8) Expand the Employee Retention Tax Credit (ERTC) created by the CARES Act (H.R. 6776),
9) Extend the QM patch to January 2022 to help avoid additional disruption to the housing market. (House and Senate)
Second Initiative - Community Bank top priorities for pandemic relief measures -
1) Support Sen. Cramers legislation (S. 4117), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less-allowing business owners to focus on their businesses and the safety of their employees and customers (protections against fraud and misrepresentation still apply).
2) Support Sen. Kings legislation (S. 4171), which would require Treasury or SBA (not a third-party) to create an easy-to-use online loan forgiveness calculator to help clear up what is a very confusing and complex application process. This would ensure borrowers and lenders protection and accuracy.
3) Support Rep. Houlahans legislation (H.R. 7777), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less-allowing business owners to focus on their businesses and the safety of their employees and customers (protections against fraud and misrepresentation still apply).
4) Support Rep. Wagners legislation (H.R. 7413), which would require Treasury or SBA (not a third-party) to create an easy-to-use online loan forgiveness calculator to help clear up what is a very confusing and complex application process. This would ensure borrowers and lenders protection and accuracy.
5) Create capacity for additional lending by requiring SBA to purchase PPP loans at par (minus the amount that has been forgiven).
6) Ensure PPP loans are not included in regulatory asset threshold calculations. If PPP lending causes our assets to exceed certain thresholds, additional regulations and supervision are triggered, causing many community banks to face costly, burdensome and unintended consequences.
7) Support Sen. Cornyns legislation (S. 3612), which would allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses, as they ordinarily would. Without this, the value of a PPP loan is effectively reduced and tax preparation is unnecessarily cumbersome.
8) Support Rep. Holdings legislation (H.R. 6821), which would allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses, as they ordinarily would. Without this, the value of a PPP loan is effectively reduced and tax preparation is unnecessarily cumbersome.
9) Enact bank capital and accounting relief measures to support borrowers and lenders facing historically challenging circumstances by extending TDR, suspending CECL and making the 8% CBLR permanent for institutions of $10 billion or less in assets. Banks strong capitalization at the beginning of the crisis means that capital and accounting could be implemented without compromising safety and soundness.
10) Create a liability safe harbor for businesses from COVID-19-related lawsuits. Community banks and small businesses have every incentive to ensure the personal safety of their employees and customers. Fear of opportunistic class actions or other suits will inhibit the restoration of economic activity.
11) Support rural America by passing Rep. Watkinss ECORA Act (H.R. 1872), which exempts interest on most agricultural loans from taxable income (lowering interest rates for farmers, ranchers and rural homeowners), provides direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhances USDA guaranteed lending programs. (House, Senate)
Letters -
Comment Letter to the National Credit Union Administration (NCUA) regarding: Subordinated Debt; Proposed Rule RIN 3133-AF08 (NCUA)
Comment Letter to the Consumer Financial Protection Bureau (CFPB) regarding: Request for Information on Equal Credit Opportunity and Regulation B; Docket No CFPB-2020-0026 (CFPB)
Action Alerts -
Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate)
#2 Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate)
Miscellaneous -
OCC proposal to issue payments charters (OCC)
Beneficial ownership reporting regulatory relief (with FinCEN - not a community bank responsibility) (House)
Postal Service financial services [banking] pilot program (House)
Community Reinvestment Act (CRA) modernization (joint rulemaking) (House)
Payments System Improvements (Federal Reserve FedNow Service) (House)
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Consumer Financial Protection Bureau (CFPB), Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Housing Finance Agency (FHFA), Natl Credit Union Administration (NCUA)
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 2020 Federal Policy Priorities -
Support The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity
Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155)
Support Additional Meaningful Regulatory Relief for Community Banks
Oppose Credit Unions Expanded Powers
Support the Federal Reserves Role in Payments System Improvement
Support Modernizing the Community Reinvestment Act (CRA)
Support Safe Harbor for Banking Cannabis-Related Businesses
Support Sound Principles for GSE Reform
Support the Federal Home Loan Banks
Support Agriculture and Rural America
Support Enhanced Data, Cyber and Payment Card Security (Data Security)
Support Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks
Support the Community Bank Positions on Emerging Issues
CFPBs Customer Data Sharing
CFPBs Small-Dollar Consumer Lending
Federal Reserves Modernize Reg CC
Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts
(House, Senate, CFPB, OCC, FDIC, Federal Reserve, FHFA)
Legislation and Regulations -
Community Bank top priorities for pandemic relief measures -
1) Support rural America by allowing interest on loans secured by agricultural real estate or primary residences in rural communities to be tax-exempt (ECORA, S.1641/H.R. 1872), providing direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhance USDA guaranteed lending programs;
2) Extend the QM patch to January 2022 to help avoid additional disruption to the housing market. (House and Senate)
Second Initiative - Community Bank top priorities for pandemic relief measures -
1) Support rural America by passing Rep. Watkinss ECORA Act (H.R. 1872), which exempts interest on most agricultural loans from taxable income (lowering interest rates for farmers, ranchers and rural homeowners), provides direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhances USDA guaranteed lending programs. (House, Senate)
FHFA/Fannie/Freddie .50% residential mortgage guarantee fee increase with a September 1, 2020 implementation date (FHFA, Federal Reserve, OCC, House, Senate)
Letters -
Comment Letter to the National Credit Union Administration (NCUA) regarding: Subordinated Debt; Proposed Rule RIN 3133-AF08 (NCUA)
Comment Letter to the Consumer Financial Protection Bureau (CFPB) regarding: Request for Information on Equal Credit Opportunity and Regulation B; Docket No CFPB-2020-0026 (CFPB)
Action Alerts -
Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate)
Action Alert regarding FHFA/Fannie/Freddie .50% residential mortgage guarantee fee increase with a September 1, 2020 implementation date (House, Senate)
#2 Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate)
Miscellaneous -
OCC proposal to issue payments charters (OCC)
Postal Service financial services [banking] pilot program (House)
Community Reinvestment Act (CRA) modernization (joint rulemaking)(House)
Payments System Improvements (Federal Reserve FedNow Service) (House)
Expiration of time to receive, and delivery of, Economic Impact Payments (EIPs) (House, Senate)
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Consumer Financial Protection Bureau (CFPB), Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Housing Finance Agency (FHFA), Natl Credit Union Administration (NCUA)
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 SMB
16. Specific lobbying issues
Community Bankers Association of Illinois 2020 Federal Policy Priorities -
Support The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity
Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155)
Support Additional Meaningful Regulatory Relief for Community Banks
Oppose Credit Unions Expanded Powers
Oppose Farm Credit Systems Expanded Powers
Support the Federal Reserves Role in Payments System Improvement
Support Modernizing the Community Reinvestment Act (CRA)
Support Safe Harbor for Banking Cannabis-Related Businesses
Support Agriculture and Rural America
Support Enhanced Data, Cyber and Payment Card Security (Data Security)
Support Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks
Support the Community Bank Positions on Emerging Issues
CFPBs Customer Data Sharing
CFPBs Small Business Data Collection
Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts
(House, Senate, CFPB, OCC, FDIC, Federal Reserve, FHFA)
Legislation and Regulation -
S. 4117 - Paycheck Protection Small Business Forgiveness Act (All Sections) Regarding Paycheck Protection Program (PPP) loans of $150,000 and under qualifying for forgiveness with one-page application (Senate)
H.R. 7777 - Paycheck Protection Small Business Forgiveness Act (All Sections) Regarding Paycheck Protection Program (PPP) loans of $150,000 and under provided automatic forgiveness (House)
Community Bank top priorities for pandemic relief measures -
1) Cosponsor legislation in the Senate and House (S. 4117 and H.R. 7777), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less;
2) Allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses. (S. 3612/H.R. 6821);
3) Enact bank capital and accounting relief measures to support borrowers and lenders facing historically challenging circumstances by extending Troubled Debt Restructuring (TDR), suspending the Current Expected Credit Loss (CECL) requirements, and making the 8% Community Bank Leverage Ratio (CBLR) permanent for institutions of $10 billion or less in assets;
4) Create capacity for additional lending by requiring SBA to purchase PPP loan at par;
5) Create a liability safe harbor for businesses from COVID-19-related lawsuits;
6) Support rural America by allowing interest on loans secured by agricultural real estate or primary residences in rural communities to be tax-exempt (ECORA, S.1641/H.R. 1872), providing direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhance USDA guaranteed lending programs;
7) Expand the Employee Retention Tax Credit (ERTC) created by the CARES Act (H.R. 6776) (House and Senate)
Second Initiative - Community Bank top priorities for pandemic relief measures -
1) Support Sen. Cramers legislation (S. 4117), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less-allowing business owners to focus on their businesses and the safety of their employees and customers (protections against fraud and misrepresentation still apply).
2) Support Sen. Kings legislation (S. 4171), which would require Treasury or SBA (not a third-party) to create an easy-to-use online loan forgiveness calculator to help clear up what is a very confusing and complex application process. This would ensure borrowers and lenders protection and accuracy.
3) Support Rep. Houlahans legislation (H.R. 7777), which would create a presumption of compliance and forgiveness based on the borrowers certification that the funds were used in accordance with the terms of the program for PPP loans with an original balance of $150,000 or less-allowing business owners to focus on their businesses and the safety of their employees and customers (protections against fraud and misrepresentation still apply).
4) Support Rep. Wagners legislation (H.R. 7413), which would require Treasury or SBA (not a third-party) to create an easy-to-use online loan forgiveness calculator to help clear up what is a very confusing and complex application process. This would ensure borrowers and lenders protection and accuracy.
5) Create capacity for additional lending by requiring SBA to purchase PPP loans at par (minus the amount that has been forgiven).
6) Ensure PPP loans are not included in regulatory asset threshold calculations. If PPP lending causes our assets to exceed certain thresholds, additional regulations and supervision are triggered, causing many community banks to face costly, burdensome and unintended consequences.
7) Support Sen. Cornyns legislation (S. 3612), which would allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses, as they ordinarily would. Without this, the value of a PPP loan is effectively reduced and tax preparation is unnecessarily cumbersome.
8) Support Rep. Holdings legislation (H.R. 6821), which would allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses, as they ordinarily would. Without this, the value of a PPP loan is effectively reduced and tax preparation is unnecessarily cumbersome.
9) Enact bank capital and accounting relief measures to support borrowers and lenders facing historically challenging circumstances by extending TDR, suspending CECL and making the 8% CBLR permanent for institutions of $10 billion or less in assets. Banks strong capitalization at the beginning of the crisis means that capital and accounting could be implemented without compromising safety and soundness.
10) Create a liability safe harbor for businesses from COVID-19-related lawsuits. Community banks and small businesses have every incentive to ensure the personal safety of their employees and customers. Fear of opportunistic class actions or other suits will inhibit the restoration of economic activity.
11) Support rural America by passing Rep. Watkinss ECORA Act (H.R. 1872), which exempts interest on most agricultural loans from taxable income (lowering interest rates for farmers, ranchers and rural homeowners), provides direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhances USDA guaranteed lending programs. (House, Senate)
Letters -
Comment Letter to the National Credit Union Administration (NCUA) regarding: Subordinated Debt; Proposed Rule RIN 3133-AF08 (NCUA)
Comment Letter to the Consumer Financial Protection Bureau (CFPB) regarding: Request for Information on Equal Credit Opportunity and Regulation B; Docket No CFPB-2020-0026 (CFPB)
Action Alerts -
Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate)
#2 Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate)
Miscellaneous -
OCC proposal to issue payments charters (OCC)
Beneficial ownership reporting regulatory relief (with FinCEN - not a community bank responsibility) (House)
Postal Service financial services [banking] pilot program (House)
Community Reinvestment Act (CRA) modernization (joint rulemaking) (House)
Payments System Improvements (Federal Reserve FedNow Service) (House)
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Consumer Financial Protection Bureau (CFPB), Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Housing Finance Agency (FHFA), Natl Credit Union Administration (NCUA)
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 TAX
16. Specific lobbying issues
Community Bankers Association of Illinois 2020 Federal Policy Priorities -
Support The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity
Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155)
Support Additional Meaningful Regulatory Relief for Community Banks
Oppose Credit Unions Expanded Powers
Oppose Farm Credit Systems Expanded Powers
Support Modernizing the Community Reinvestment Act (CRA)
Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts
(House, Senate, CFPB, OCC, FDIC, Federal Reserve, FHFA)
Legislation and Regulation -
Community Bank top priorities for pandemic relief measures -
1) Allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses. (S. 3612/H.R. 6821);
2) Support local regions by raising the current bank-qualified municipal bond annual issuance limit to $50 million from $10 million to expedite low-cost funding for local projects;
3) Support rural America by allowing interest on loans secured by agricultural real estate or primary residences in rural communities to be tax-exempt (ECORA, S.1641/H.R. 1872), providing direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhance USDA guaranteed lending programs;
4) Expand the Employee Retention Tax Credit (ERTC) created by the CARES Act (H.R. 6776) (House and Senate)
Second Initiative - Community Bank top priorities for pandemic relief measures -
1) Support Sen. Cornyns legislation (S. 3612), which would allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses, as they ordinarily would. Without this, the value of a PPP loan is effectively reduced and tax preparation is unnecessarily cumbersome.
2) Support Rep. Holdings legislation (H.R. 6821), which would allow small business PPP borrowers that obtain loan forgiveness to deduct payroll and other business expenses, as they ordinarily would. Without this, the value of a PPP loan is effectively reduced and tax preparation is unnecessarily cumbersome.
3) Support rural America by passing Rep. Watkinss ECORA Act (H.R. 1872), which exempts interest on most agricultural loans from taxable income (lowering interest rates for farmers, ranchers and rural homeowners), provides direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhances USDA guaranteed lending programs. (House, Senate)
Letters -
Comment Letter to the National Credit Union Administration (NCUA) regarding: Subordinated Debt; Proposed Rule RIN 3133-AF08 (NCUA)
Action Alerts -
Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate)
#2 Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate)
Miscellaneous -
Community Reinvestment Act (CRA) modernization (joint rulemaking) (House)
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Consumer Financial Protection Bureau (CFPB), Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Housing Finance Agency (FHFA), Natl Credit Union Administration (NCUA)
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 ECN
16. Specific lobbying issues
Community Bankers Association of Illinois 2020 Federal Policy Priorities -
Support The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity
Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155)
Support Additional Meaningful Regulatory Relief for Community Banks
Oppose Credit Unions Expanded Powers
Oppose Farm Credit Systems Expanded Powers
Support the Federal Reserves Role in Payments System Improvement
Support Modernizing the Community Reinvestment Act (CRA)
Support Agriculture and Rural America
Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts
(House, Senate, CFPB, OCC, FDIC, Federal Reserve, FHFA)
Legislation and Regulation -
Community Bank top priorities for pandemic relief measures -
1) Support local regions by raising the current bank-qualified municipal bond annual issuance limit to $50 million from $10 million to expedite low-cost funding for local projects;
2) Support rural America by allowing interest on loans secured by agricultural real estate or primary residences in rural communities to be tax-exempt (ECORA, S.1641/H.R. 1872), providing direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhance USDA guaranteed lending programs (House and Senate)
Second Initiative - Community Bank top priorities for pandemic relief measures -
1) Support rural America by passing Rep. Watkinss ECORA Act (H.R. 1872), which exempts interest on most agricultural loans from taxable income (lowering interest rates for farmers, ranchers and rural homeowners), provides direct assistance to farmers, ranchers and others involved in the food sector as needed, and enhances USDA guaranteed lending programs. (House, Senate)
Letters -
Comment Letter to the National Credit Union Administration (NCUA) regarding: Subordinated Debt; Proposed Rule RIN 3133-AF08 (NCUA)
Action Alerts -
Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate)
#2 Action Alert regarding urging Illinois Members of Congress to support additional pandemic relief as noted above in the Legislation and Regulation section of this filing (House, Senate)
Miscellaneous -
Community Reinvestment Act (CRA) modernization (joint rulemaking) (House)
Payments System Improvements (Federal Reserve FedNow Service) (House)
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Consumer Financial Protection Bureau (CFPB), Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Housing Finance Agency (FHFA), Natl Credit Union Administration (NCUA)
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
Information Update Page - Complete ONLY where registration information has changed.
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LOBBYIST UPDATE
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AFFILIATED ORGANIZATIONS
25. Add the following affiliated organization(s)
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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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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?
| Lobbyist Name | Description of Offense(s) |