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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 | 2018 |
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 | 4/19/2019 10:36:11 AM |
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
Regulatory relief for community banks in the 115th Congress
Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity
The ICBAs Plan for Prosperity contains the following issue areas and recommendations.
Access to Capital
Restore the original intent of the Basel III rule
Create a more accurate identification of systemic risk
Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement
Relieve community banks from excessive Securities and Exchange Commission rules
Repeal the Collins Amendment for non-SIFIs
Address minority bank capital challenges
Regulatory Relief
Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance
Eliminate arbitrary disparate impact fair lending lawsuits
Ensure the viability of mutual banks through new charter and capital options
Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed
Modernize the Bank Secrecy Act (BSA)
Cut the red tape in small business lending by eliminating burdensome data collection
Target the Volker Rule on a banks individual risk
Preserve access to investment advice for middle-class savers
Mortgage Reform
Create a safe harbor from onerous underwriting standards
Establish relief from burdensome HMDA, escrow and appraisal requirements
Preserve the ability for community banks to continue servicing mortgage loans
Reform the closing process and accompanying paperwork
Bank Oversight and Examination
Strengthen accountability in bank exams and create a workable appeals process
Reform bank oversight and examination to better target risk
Tax Relief
Lower marginal rates needed for individuals, corporations and businesses
Incentivize credit for low- and middle-income customers and American agriculture
Modernize Subchapter S constraints
Create limited liability corporation (LLC) option for community banks
Repeal the estate tax
Update the bank qualified (BQ) bond issuer limitation
Support a five-year loss carryback that encourages lending during economic downturns
Create a tax credit for Bank Secrecy Act (BSA) compliance costs
Agriculture and Rural America
Address arbitrary agricultural loan concentration limits
Institute tax relief for rural lending
(House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Legislation -
H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance and USDA lending limits (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Senate version of H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance and USDA lending limits (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Letters -
Comment Letter to the OCC regarding Reforming the Community Reinvestment Act Regulatory Framework, Docket ID OCC-2018-0008 and RIN 1557-AE34 (OCC)
Letter to Congress regarding H.R. 2, the Agricultural Improvement Act of 2018 regarding crop insurance and conservations, expansion in foreign markets, and research and development (House and Senate)
Comment Letter to the Federal Reserve Board regarding Potential Federal Reserve Actions to Support Interbank Settlement of faster Payments, Docket No. OP-1625 (Federal Reserve Board, Federal Reserve Bank of Cleveland, Kansas City)
Miscellaneous -
Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following - 201 (QM for portfolio loans), 103 (appraisal in rural areas), 104 (HMDA adjustments), 108 (escrow requirements), 109 (no wait 3 day TILA-RESPA mortgage disclosure), 201 (capital simplification), 202 (reciprocal deposits), 203 (Volcker Rule), 205 (short-form Call Report), 206 (Federal Savings Associations options), 201 (examination cycles), 214 (definitions and risk weights for HVCRE and ADC loans), 401 (enhanced supervision for certain HCs), 403 (treatment of muni obligations (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Bank Secrecy Act (BSA) modernization - Currency Transaction Report (CTR) threshold (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Tax credit to offset the cost of BSA compliance (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
The Federal Reserves Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Modification of the FDICs Deposit Rate Caps (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions in CRA compliance, examination and enforcement (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Principals of GSE Reform (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Agriculture and rural America / rural economic development (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Expansionist Agenda of Credit Unions (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Expansionist Agenda of the Farm Credit System (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Implementation of the Current Expected Credit Loss (CECL) model (OCC)
On-line business lending disclosures (Senate)
Short-form Call Report for first and third quarters of a year (Senate)
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC), Federal Reserve System, Consumer Financial Protection Bureau (CFPB), Federal Housing Finance Agency (FHFA)
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
Regulatory relief for community banks in the 115th Congress
Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity
The ICBAs Plan for Prosperity contains the following issue areas and recommendations.
Access to Capital
Restore the original intent of the Basel III rule
Create a more accurate identification of systemic risk
Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement
Relieve community banks from excessive Securities and Exchange Commission rules
Repeal the Collins Amendment for non-SIFIs
Address minority bank capital challenges
Regulatory Relief
Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance
Eliminate arbitrary disparate impact fair lending lawsuits
Ensure the viability of mutual banks through new charter and capital options
Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed
Modernize the Bank Secrecy Act (BSA)
Cut the red tape in small business lending by eliminating burdensome data collection
Target the Volker Rule on a banks individual risk
Preserve access to investment advice for middle-class savers
Mortgage Reform
Create a safe harbor from onerous underwriting standards
Establish relief from burdensome HMDA, escrow and appraisal requirements
Preserve the ability for community banks to continue servicing mortgage loans
Reform the closing process and accompanying paperwork
Bank Oversight and Examination
Strengthen accountability in bank exams and create a workable appeals process
Reform bank oversight and examination to better target risk
Tax Relief
Lower marginal rates needed for individuals, corporations and businesses
Incentivize credit for low- and middle-income customers and American agriculture
Modernize Subchapter S constraints
Create limited liability corporation (LLC) option for community banks
Repeal the estate tax
Update the bank qualified (BQ) bond issuer limitation
Support a five-year loss carryback that encourages lending during economic downturns
Create a tax credit for Bank Secrecy Act (BSA) compliance costs
Agriculture and Rural America
Address arbitrary agricultural loan concentration limits
Institute tax relief for rural lending
(House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Legislation -
H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance and USDA lending limits (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Senate version of H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance and USDA lending limits (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Letters -
Comment Letter to the OCC regarding Reforming the Community Reinvestment Act Regulatory Framework, Docket ID OCC-2018-0008 and RIN 1557-AE34 (OCC)
Letter to Congress regarding H.R. 2, the Agricultural Improvement Act of 2018 regarding crop insurance and conservations, expansion in foreign markets, and research and development (House and Senate)
Comment Letter to the Federal Reserve Board regarding Potential Federal Reserve Actions to Support Interbank Settlement of faster Payments, Docket No. OP-1625 (Federal Reserve Board, Federal Reserve Bank of Cleveland, Kansas City)
Miscellaneous -
Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following - 201 (QM for portfolio loans), 103 (appraisal in rural areas), 104 (HMDA adjustments), 108 (escrow requirements), 109 (no wait 3 day TILA-RESPA mortgage disclosure), 201 (capital simplification), 202 (reciprocal deposits), 203 (Volcker Rule), 205 (short-form Call Report), 206 (Federal Savings Associations options), 201 (examination cycles), 214 (definitions and risk weights for HVCRE and ADC loans), 401 (enhanced supervision for certain HCs), 403 (treatment of muni obligations (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Bank Secrecy Act (BSA) modernization - Currency Transaction Report (CTR) threshold (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Tax credit to offset the cost of BSA compliance (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
The Federal Reserves Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Modification of the FDICs Deposit Rate Caps (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions in CRA compliance, examination and enforcement (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Principals of GSE Reform (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Agriculture and rural America / rural economic development (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Expansionist Agenda of Credit Unions (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Expansionist Agenda of the Farm Credit System (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Implementation of the Current Expected Credit Loss (CECL) model (OCC)
On-line business lending disclosures (Senate)
Short-form Call Report for first and third quarters of a year (Senate)
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Consumer Financial Protection Bureau (CFPB), Federal Housing Finance Agency (FHFA), 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
Regulatory relief for community banks in the 115th Congress
Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity
The ICBAs Plan for Prosperity contains the following issue areas and recommendations.
Agriculture and Rural America
Address arbitrary agricultural loan concentration limits
Institute tax relief for rural lending
(House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Legislation -
H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance and USDA lending limits (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Senate version of H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance and USDA lending limits (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Letters -
Comment Letter to the OCC regarding Reforming the Community Reinvestment Act Regulatory Framework, Docket ID OCC-2018-0008 and RIN 1557-AE34 (OCC)
Letter to Congress regarding H.R. 2, the Agricultural Improvement Act of 2018 regarding crop insurance and conservations, expansion in foreign markets, and research and development (House and Senate)
Miscellaneous -
Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following - 201 (QM for portfolio loans), 103 (appraisal in rural areas), 104 (HMDA adjustments), 108 (escrow requirements), 109 (no wait 3 day TILA-RESPA mortgage disclosure), 201 (capital simplification), 202 (reciprocal deposits), 203 (Volcker Rule), 205 (short-form Call Report), 206 (Federal Savings Associations options), 201 (examination cycles), 214 (definitions and risk weights for HVCRE and ADC loans), 401 (enhanced supervision for certain HCs), 403 (treatment of muni obligations (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
The Federal Reserves Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions in CRA compliance, examination and enforcement (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Principals of GSE Reform (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Agriculture and rural America / rural economic development (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Expansionist Agenda of the Farm Credit System (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC), Federal Reserve System, Consumer Financial Protection Bureau (CFPB), Federal Housing Finance Agency (FHFA)
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
Regulatory relief for community banks in the 115th Congress
Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity
The ICBAs Plan for Prosperity contains the following issue areas and recommendations.
Regulatory Relief
Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance
Eliminate arbitrary disparate impact fair lending lawsuits
Ensure the viability of mutual banks through new charter and capital options
Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed
Modernize the Bank Secrecy Act (BSA)
Cut the red tape in small business lending by eliminating burdensome data collection
Target the Volker Rule on a banks individual risk
Preserve access to investment advice for middle-class savers
Mortgage Reform
Create a safe harbor from onerous underwriting standards
Establish relief from burdensome HMDA, escrow and appraisal requirements
Preserve the ability for community banks to continue servicing mortgage loans
Reform the closing process and accompanying paperwork
Tax Relief
Lower marginal rates needed for individuals, corporations and businesses
Incentivize credit for low- and middle-income customers and American agriculture
Modernize Subchapter S constraints
Create limited liability corporation (LLC) option for community banks
Repeal the estate tax
Update the bank qualified (BQ) bond issuer limitation
Support a five-year loss carryback that encourages lending during economic downturns
Create a tax credit for Bank Secrecy Act (BSA) compliance costs
(House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Letters -
Comment Letter to the OCC regarding Reforming the Community Reinvestment Act Regulatory Framework, Docket ID OCC-2018-0008 and RIN 1557-AE34 (OCC)
Miscellaneous -
Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following - 201 (QM for portfolio loans), 103 (appraisal in rural areas), 104 (HMDA adjustments), 108 (escrow requirements), 109 (no wait 3 day TILA-RESPA mortgage disclosure), 201 (capital simplification), 202 (reciprocal deposits), 203 (Volcker Rule), 205 (short-form Call Report), 206 (Federal Savings Associations options), 201 (examination cycles), 214 (definitions and risk weights for HVCRE and ADC loans), 401 (enhanced supervision for certain HCs), 403 (treatment of muni obligations (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Bank Secrecy Act (BSA) modernization - Currency Transaction Report (CTR) threshold (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
The Federal Reserves Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions in CRA compliance, examination and enforcement (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Principals of GSE Reform (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Agriculture and rural America / rural economic development (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Expansionist Agenda of Credit Unions (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC), Federal Reserve System, Consumer Financial Protection Bureau (CFPB), Federal Housing Finance Agency (FHFA)
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
Regulatory relief for community banks in the 115th Congress
Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity
The ICBAs Plan for Prosperity contains the following issue areas and recommendations.
Access to Capital
Restore the original intent of the Basel III rule
Create a more accurate identification of systemic risk
Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement
Relieve community banks from excessive Securities and Exchange Commission rules
Repeal the Collins Amendment for non-SIFIs
Address minority bank capital challenges
Regulatory Relief
Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance
Eliminate arbitrary disparate impact fair lending lawsuits
Ensure the viability of mutual banks through new charter and capital options
Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed
Modernize the Bank Secrecy Act (BSA)
Cut the red tape in small business lending by eliminating burdensome data collection
Target the Volker Rule on a banks individual risk
Preserve access to investment advice for middle-class savers
Tax Relief
Lower marginal rates needed for individuals, corporations and businesses
Incentivize credit for low- and middle-income customers and American agriculture
Modernize Subchapter S constraints
Create limited liability corporation (LLC) option for community banks
Repeal the estate tax
Update the bank qualified (BQ) bond issuer limitation
Support a five-year loss carryback that encourages lending during economic downturns
Create a tax credit for Bank Secrecy Act (BSA) compliance costs
Agriculture and Rural America
Address arbitrary agricultural loan concentration limits
Institute tax relief for rural lending
(House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Legislation -
H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance and USDA lending limits (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Senate version of H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance and USDA lending limits (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Letters -
Comment Letter to the OCC regarding Reforming the Community Reinvestment Act Regulatory Framework, Docket ID OCC-2018-0008 and RIN 1557-AE34 (OCC)
Miscellaneous -
Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following - 201 (QM for portfolio loans), 103 (appraisal in rural areas), 104 (HMDA adjustments), 108 (escrow requirements), 109 (no wait 3 day TILA-RESPA mortgage disclosure), 201 (capital simplification), 202 (reciprocal deposits), 203 (Volcker Rule), 205 (short-form Call Report), 206 (Federal Savings Associations options), 201 (examination cycles), 214 (definitions and risk weights for HVCRE and ADC loans), 401 (enhanced supervision for certain HCs), 403 (treatment of muni obligations (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Bank Secrecy Act (BSA) modernization - Currency Transaction Report (CTR) threshold (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Tax credit to offset the cost of BSA compliance (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
The Federal Reserves Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Modification of the FDICs Deposit Rate Caps (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions in CRA compliance, examination and enforcement (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Agriculture and rural America / rural economic development (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Expansionist Agenda of Credit Unions (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Expansionist Agenda of the Farm Credit System (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
On-line business lending disclosures (Senate)
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC), Federal Reserve System, Consumer Financial Protection Bureau (CFPB), Federal Housing Finance Agency (FHFA)
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
Regulatory relief for community banks in the 115th Congress
Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity
The ICBAs Plan for Prosperity contains the following issue areas and recommendations.
Tax Relief
Lower marginal rates needed for individuals, corporations and businesses
Incentivize credit for low- and middle-income customers and American agriculture
Modernize Subchapter S constraints
Create limited liability corporation (LLC) option for community banks
Repeal the estate tax
Update the bank qualified (BQ) bond issuer limitation
Support a five-year loss carryback that encourages lending during economic downturns
Create a tax credit for Bank Secrecy Act (BSA) compliance costs
Agriculture and Rural America
Address arbitrary agricultural loan concentration limits
Institute tax relief for rural lending
(House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Legislation -
Comment Letter to the OCC regarding Reforming the Community Reinvestment Act Regulatory Framework, Docket ID OCC-2018-0008 and RIN 1557-AE34 (House, OCC, Federal Reserve, FDIC)
Miscellaneous -
Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following - 201 (QM for portfolio loans), 103 (appraisal in rural areas), 104 (HMDA adjustments), 108 (escrow requirements), 109 (no wait 3 day TILA-RESPA mortgage disclosure), 201 (capital simplification), 202 (reciprocal deposits), 203 (Volcker Rule), 205 (short-form Call Report), 206 (Federal Savings Associations options), 201 (examination cycles), 214 (definitions and risk weights for HVCRE and ADC loans), 401 (enhanced supervision for certain HCs), 403 (treatment of muni obligations (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Tax credit to offset the cost of BSA compliance (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Expansionist Agenda of Credit Unions (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Expansionist Agenda of the Farm Credit System (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC), Federal Reserve System, Consumer Financial Protection Bureau (CFPB), Federal Housing Finance Agency (FHFA)
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
Letters -
Comment Letter to the OCC regarding Reforming the Community Reinvestment Act Regulatory Framework, Docket ID OCC-2018-0008 and RIN 1557-AE34 (OCC)
Miscellaneous -
Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions in CRA compliance, examination and enforcement (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
Agriculture and rural America / rural economic development (House, Senate, FDIC, OCC, Federal Reserve, CFPB, FHFA)
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC), Federal Reserve System, Consumer Financial Protection Bureau (CFPB), Federal Housing Finance Agency (FHFA)
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.
20. Client new address
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21. Client new principal place of business (if different than line 20)
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22. New General description of client’s business or activities
LOBBYIST UPDATE
23. Name of each previously reported individual who is no longer expected to act as a lobbyist for the client
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ISSUE UPDATE
24. General lobbying issue that no longer pertains
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AFFILIATED ORGANIZATIONS
25. Add the following affiliated organization(s)
Internet Address:
| Name | Address |
Principal Place of Business (city and state or country) |
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26. Name of each previously reported organization that is no longer affiliated with the registrant or client
| 1 | 2 | 3 |
FOREIGN ENTITIES
27. Add the following foreign entities:
| Name | Address |
Principal place of business (city and state or country) |
Amount of contribution for lobbying activities | Ownership percentage in client | ||||||||||
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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
| 1 | 3 | 5 |
| 2 | 4 | 6 |
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) |