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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
| Address1 | 3138 NORTH 10TH STREET |
Address2 |
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| City | ARLINGTON |
State | VA |
Zip Code | 22201 |
Country | USA |
3. Principal place of business (if different than line 2)
| City | Arlington |
State | VA |
Zip Code | 22201 |
Country | USA |
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5. Senate ID# 26763-12
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6. House ID# 302630000
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| TYPE OF REPORT | 8. Year | 2023 |
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 | 12/31/2023 |
11. No Lobbying Issue Activity |
| INCOME OR EXPENSES - YOU MUST complete either Line 12 or Line 13 | |||||||||
|---|---|---|---|---|---|---|---|---|---|
| 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: Greg Mesack |
Date | 1/22/2024 3:20:36 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
Protect the credit union tax exemption;
Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their nearly 140 million members;
Support regulatory relief for credit unions;
Provide guidance or rulemakings rather than rule through enforcement;
Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight;
Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies;
Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members;
Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper;
Support increase in funding for CDFI Fund, MDIs, and the CDRLF;
Support extending GLBA-like data security measures to retailers and fintechs;
Support recognizing GLBA compliance in any privacy legislation;
Oppose private right of action in data privacy legislation;
Support NCUA as credit unions sole data privacy regulator;
Oppose opt-in requirement for use of non-public personal information in data privacy legislation;
Support federal preemption of state data privacy laws;
Oppose NCUA examination authority for 3rd party vendors;
Oppose NCUA adopting a dedicated consumer compliance examination;
Support extended NCUA examination cycle;
Support NCUA Central Liquidity Facility (CLF) improvements;
Support vendor information sharing among financial regulators;
Support NCUA independence as regulator and insurer;
Oppose unsustainable NCUA budget growth;
Support increased NCUA assistance for MDI credit unions;
Support adjusting Dodd-Frank Act thresholds for inflation;
Support legislative action to limit Regulation E liability;
Support fair distribution of Regulation E error resolution responsibilities;
Support greater investment authorities for credit unions;
Support expansion of Low-Income Housing Tax Credit;
Support publication of list of entities with access to Federal Reserve Bank accounts and services;
Support legislative action to clarify CFPBs UDAAP authority;
Support parity in credit union and bank federal deposit insurance levels;
Oppose increased NCUA authority to charge share insurance premiums;
Oppose SBA direct lending authority;
Oppose fintech participation in SBA lending programs;
Prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products;
CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate;
Support increased CFPB transparency in rulemaking, supervision, and enforcement;
Support CFPB coordination with NCUA in policymaking;
Support CFPB basing policy on thorough research and data analysis;
CFPB should engage in interagency coordination on Section 1033 consumer access to financial records rulemaking;
Oppose CFPBs characterization of regulated and disclosed financial services fees as junk fees;
CFPB should explore streamlining required fee disclosures;
Oppose mandatory grace period for credit card late payments;
CFPB should clarify UDAAP authority;
CFPB should respect GLBAs data security regulatory structure;
CFPB should limit impact and burden from final rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09);
Support prohibiting CFPB expending funds to implement the Section 1071 Small Business Lending Data Collection final rule (RIN: 3170-AA09);
Improve examination coordination between CFPB and NCUA;
Support CFPB exercise of larger participant authority to oversee fintech companies;
Support clear regulatory framework for digital assets to encourage responsible innovation and permit credit union participation;
Support CDFI Fund transparency on certification changes;
Oppose changes to CDFI Fund certification process;
Support Congressional oversight of SBAs Affiliation and Small Business Lending Company final rules;
Support legislation to limit impact of SBAs Affiliation and Small Business Lending Company final rules;
Support tax deduction for mortgage insurance premiums;
Support modification or removal of the credit union member business lending cap;
Support increasing credit union loan maturity limits;
Support allowing credit unions to add underserved areas to their FOM;
Support removing service area requirement for FOM expansion;
Support increasing the credit union interest rate ceiling;
Oppose national all-in interest rate cap;
Oppose expanding the Fair Debt Collection Practices Act to cover business loans;
Support credit union Community Reinvestment Act exemption;
Support regulator-approved credit union mergers;
Support regulations adhering to intent of the Fair Credit Reporting Act;
Support regulation of credit reporting agencies and credit repair organizations;
Oppose legislation granting for-profit banks nominal leases on military installations;
Support credit union access to nominal leases on military installations;
Support alternative credit scoring models;
Oppose exclusion of accurate information from credit reports;
Support FinCEN funding;
Support FinCEN oversight;
Support increasing SAR and CTR thresholds;
Support disbursal of ECIP funding;
Oppose NCUA acting as a climate regulator;
Support credit union eligibility for the Greenhouse Gas Reduction Fund;
Support Congressional oversight of the Federal Reserve Overnight Reverse Repo Facility;
FCC should tailor robocall and robotext regulations to allow credit unions to serve their members;
Support placing CFPB under regular appropriations process;
FHFA should allow GSEs to purchase non-conforming loans from CDFIs and consider wealth-building home loan pilot programs;
Oppose increase in FHFA guarantee fees;
Support elimination of guarantee fees for credit union mortgages;
Support regulation of fintechs in mortgage lending;
Support alternative credit scoring models;
Oppose development of a CBDC;
Support prevention of an NFIP lapse;
Support improving veterans access to capital by exempting credit unions business loans to veterans from the credit union member business lending cap;
Support expanding the definition of Community Financial Institutions (CFIs) in the Federal Home Loan Bank Act (FHLB Act) to include credit unions and Treasury-certified non-depository community development financial institutions;
Support government guarantees to stabilize mortgage-backed securities market;
Support pilot programs for wealth-building home loans and zero-down mortgages;
Support quality- rather than quantity-based GSE loan pricing;
Oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation;
Support parity for credit unions related to stablecoin regulation;
Treasury should address the demand for coins to help consumers who rely on cash transactions;
Support addressing appraisal bias and modernize the appraisal process for consistency;
Support easing requirements for de novo credit unions;
Support providing flexibility for credit unions to issue subordinated debt;
Support improvements to ease the process for forgiveness of PPP loans to small businesses;
Oppose limits on fee income for credit unions including courtesy pay;
Support limiting burdens of HMDA rule on credit unions;
CFPB should remove unnecessary and unused data points related to HMDA reporting;
Support permanently increasing reporting thresholds for open- and closed-end loans;
Support permanent adoption of CFPBs expired temporary relief of E-SIGN regulation;
Oppose Federal Reserve proposal to decrease debit interchange fee cap (Docket No. R‐1818);
Support for forced arbitration - studies show consumers benefit more often from arbitration than litigation;
Support Credit Union Board Modernization Act (H.R. 582; S. 610);
Support Promoting Access to Capital in Underbanked Communities Act (H.R. 758);
Support Promoting New and Diverse Depository Institutions Act (H.R. 1533; S. 2252);
Support Consumer Financial Protection Commission Act (H.R. 1410);
Support SECURE Notarization Act (H.R. 1059; S. 1212);
Support Prohibiting IRS Financial Surveillance Act (H.R. 1010; S. 453);
Support CBDC Anti-Surveillance State Act (H.R. 1122; H.R. 5403);
Support Data Privacy Act (H.R. 1165);
Support Veterans Member Business Loan Act (S. 539; H.R. 4867);
Support NCUA Central Liquidity Facility Enhancements (S. 544);
Support Neighborhood Homes Investment Act (S. 657);
Support CDFI Bond Guarantee Program Improvement Act (S. 869);
Support Small LENDER Act (H.R. 1806);
Support Transparency in CFPB Cost-Benefit Analysis Act (H.R. 1313);
Support Making the CFPB Accountable to Small Businesses Act (H.R. 1749);
Support Resolution of Disapproval of the CFPBs Section 1071 final rule (H.J.Res. 50; H.J.Res. 66; H.J.Res. 85; S.J.Res. 32)
Support CFPB Transparency and Accountability Reform Act (H.R. 2798);
Support SAFE Banking Act (H.R. 2891; S. 1323);
Support CDFI Fund Transparency Act (H.R. 3161; S. 2674);
Support Building Credit Access for Veterans Act (H.R. 1266);
Support Increasing Financial Regulatory Accountability and Transparency Act (H.R. 3556);
Support Middle Class Borrower Protection Act (H.R. 3564; S. 2296);
Support Digital Dollar Pilot Prevention Act (H.R. 3712);
Oppose Credit Card Competition Act (H.R. 3881; S. 1838);
Support Member Business Loan Expansion Act (H.R. 4868);
Oppose Senate NDAA amendments on interchange (#177; #425);
Support Clarity for Payment Stablecoins Act (H.R. 4766);
Support Senate NDAA amendment on financial literacy (#206);
Support Homes for Every Local Protector, Educator, and Responder (HELPER) Act (H.R. 3170; S. 1514);
Oppose Senate appropriations amendment on interchange (#1161);
Oppose Senate appropriations amendments on interest rate caps (#1225; #1285);
Oppose Capping Credit Card Interest Rates Act (S. 2760);
Support SAFER Banking Act (S. 2860);
Oppose Amendment #117 to H.R. 4664;
Support Amendment #174 to H.R. 4664;
Support provisions of H.R. 4664 to place CFPB under the regular appropriations process and restructure the Bureau to a bipartisan commission;
Support Rectifying UDAAP Act (H.R. 6789);
Support Close the Shadow Banking Loophole Act (S. 3538);
Oppose Predatory Lending Elimination Act (S. 3549);
Comments to NCUA on OMB Number: 3133-NEW supporting streamlined speaker request forms and increased transparency in speaker request process;
Comments to Office of the National Cyber Director on RIN: 0301-AA00 supporting regulatory harmonization and minimizing overlapping or conflicting requirements;
Comments to CFPB on Outline of FCRA Proposals supporting adherence to Congressional intent and reissuance of proposals with more detail and specificity;
Comments to Department of Labor on RIN 1235-AA39 opposing automatic adjustments and encouraging accommodation of smaller credit unions;
Comments to NCUA on proposed 2024-2025 budget opposing unsustainable budget increases and encouraging cost-savings and transparency;
Comments to OMB on OMB-2023-0020 supporting increased transparency on agencies use of artificial intelligence technology;
Comments to NCUA on Docket No. NCUA-2023-0082 supporting simplification of share insurance for trust accounts;
Comments to CFPB on Docket No. CFPB-2023-0052 opposing the proposal and urging CFPB to reduce burden on credit unions and adopt a safe harbor for data providers;
Support FHFA publishing data and analysis related to credit score model validation;
Support regulatory cost-benefit analysis that includes cumulative effects of regulations;
Support extension of comment deadline for Federal Reserve proposal on decreasing the debit interchange fee cap (Docket No. R‐1818);
Support extension of comment deadline for CFPB proposal on personal financial data rights (Docket No. CFPB-2023-0052);
Support CFPB transparency on its use of artificial intelligence technology;
Support NCUA transparency on initiatives to support financial technology innovation;
Support NCUA creating a regulatory sandbox to support financial technology innovation;
Support a delay in the effective date for the CFPBs Section 1071 final rule for all covered entities;
Support NCUA raising commercial loan threshold to $250,000 from current level of $50,000;
Support CFPB convening SBREFA panels for credit card late fee rulemaking;
Oppose Regulation E liability for financial institutions for consumer-authorized transactions;
Support FHFA reopening seasoned bulk transactions window.
17. House(s) of Congress and Federal agencies Check if None
Natl Credit Union Administration (NCUA), Small Business Administration (SBA), Defense - Dept of (DOD), Federal Reserve System, Treasury - Dept of, Securities & Exchange Commission (SEC), Housing & Urban Development - Dept of (HUD), Government Accountability Office (GAO), White House Office, Federal Housing Finance Agency (FHFA), Consumer Financial Protection Bureau (CFPB), Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Federal Communications Commission (FCC), Labor - Dept of (DOL), Veterans Affairs - Dept of (VA), Environmental Protection Agency (EPA)
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Dan |
Berger |
|
|
|
Brad |
Thaler |
|
|
|
Chad |
Adams |
|
|
|
Ann |
Kossachev |
|
|
|
Andrew |
Morris |
|
|
|
James |
Akin |
|
|
|
Clark |
Derrington |
|
|
|
Greg |
Mesack |
|
|
|
Allyson |
Gale |
|
|
|
Amber |
Milenkevich |
|
|
|
Amanda |
Smith |
|
LA for Rep. John Carney |
19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code FIN
16. Specific lobbying issues
Protect the credit union tax exemption;
Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their nearly 140 million members;
Support regulatory relief for credit unions;
Provide guidance or rulemakings rather than rule through enforcement;
Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight;
Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies;
Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members;
Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper;
Support increase in funding for CDFI Fund, MDIs, and the CDRLF;
Support extending GLBA-like data security measures to retailers and fintechs;
Support recognizing GLBA compliance in any privacy legislation;
Oppose private right of action in data privacy legislation;
Support NCUA as credit unions sole data privacy regulator;
Oppose opt-in requirement for use of non-public personal information in data privacy legislation;
Support federal preemption of state data privacy laws;
Oppose NCUA examination authority for 3rd party vendors;
Oppose NCUA adopting a dedicated consumer compliance examination;
Support extended NCUA examination cycle;
Support NCUA Central Liquidity Facility (CLF) improvements;
Support vendor information sharing among financial regulators;
Support NCUA independence as regulator and insurer;
Oppose unsustainable NCUA budget growth;
Support increased NCUA assistance for MDI credit unions;
Support adjusting Dodd-Frank Act thresholds for inflation;
Support legislative action to limit Regulation E liability;
Support fair distribution of Regulation E error resolution responsibilities;
Support greater investment authorities for credit unions;
Support expansion of Low-Income Housing Tax Credit;
Support publication of list of entities with access to Federal Reserve Bank accounts and services;
Support legislative action to clarify CFPBs UDAAP authority;
Support parity in credit union and bank federal deposit insurance levels;
Oppose increased NCUA authority to charge share insurance premiums;
Oppose SBA direct lending authority;
Oppose fintech participation in SBA lending programs;
Prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products;
CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate;
Support increased CFPB transparency in rulemaking, supervision, and enforcement;
Support CFPB coordination with NCUA in policymaking;
Support CFPB basing policy on thorough research and data analysis;
CFPB should engage in interagency coordination on Section 1033 consumer access to financial records rulemaking;
Oppose CFPBs characterization of regulated and disclosed financial services fees as junk fees;
CFPB should explore streamlining required fee disclosures;
Oppose mandatory grace period for credit card late payments;
CFPB should clarify UDAAP authority;
CFPB should respect GLBAs data security regulatory structure;
CFPB should limit impact and burden from final rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09);
Support prohibiting CFPB expending funds to implement the Section 1071 Small Business Lending Data Collection final rule (RIN: 3170-AA09);
Improve examination coordination between CFPB and NCUA;
Support CFPB exercise of larger participant authority to oversee fintech companies;
Support clear regulatory framework for digital assets to encourage responsible innovation and permit credit union participation;
Support CDFI Fund transparency on certification changes;
Oppose changes to CDFI Fund certification process;
Support Congressional oversight of SBAs Affiliation and Small Business Lending Company final rules;
Support legislation to limit impact of SBAs Affiliation and Small Business Lending Company final rules;
Support tax deduction for mortgage insurance premiums;
Support modification or removal of the credit union member business lending cap;
Support increasing credit union loan maturity limits;
Support allowing credit unions to add underserved areas to their FOM;
Support removing service area requirement for FOM expansion;
Support increasing the credit union interest rate ceiling;
Oppose national all-in interest rate cap;
Oppose expanding the Fair Debt Collection Practices Act to cover business loans;
Support credit union Community Reinvestment Act exemption;
Support regulator-approved credit union mergers;
Support regulations adhering to intent of the Fair Credit Reporting Act;
Support regulation of credit reporting agencies and credit repair organizations;
Oppose legislation granting for-profit banks nominal leases on military installations;
Support credit union access to nominal leases on military installations;
Support alternative credit scoring models;
Oppose exclusion of accurate information from credit reports;
Support FinCEN funding;
Support FinCEN oversight;
Support increasing SAR and CTR thresholds;
Support disbursal of ECIP funding;
Oppose NCUA acting as a climate regulator;
Support credit union eligibility for the Greenhouse Gas Reduction Fund;
Support Congressional oversight of the Federal Reserve Overnight Reverse Repo Facility;
FCC should tailor robocall and robotext regulations to allow credit unions to serve their members;
Support placing CFPB under regular appropriations process;
FHFA should allow GSEs to purchase non-conforming loans from CDFIs and consider wealth-building home loan pilot programs;
Oppose increase in FHFA guarantee fees;
Support elimination of guarantee fees for credit union mortgages;
Support regulation of fintechs in mortgage lending;
Support alternative credit scoring models;
Oppose development of a CBDC;
Support prevention of an NFIP lapse;
Support improving veterans access to capital by exempting credit unions business loans to veterans from the credit union member business lending cap;
Support expanding the definition of Community Financial Institutions (CFIs) in the Federal Home Loan Bank Act (FHLB Act) to include credit unions and Treasury-certified non-depository community development financial institutions;
Support government guarantees to stabilize mortgage-backed securities market;
Support pilot programs for wealth-building home loans and zero-down mortgages;
Support quality- rather than quantity-based GSE loan pricing;
Oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation;
Support parity for credit unions related to stablecoin regulation;
Treasury should address the demand for coins to help consumers who rely on cash transactions;
Support addressing appraisal bias and modernize the appraisal process for consistency;
Support easing requirements for de novo credit unions;
Support providing flexibility for credit unions to issue subordinated debt;
Support improvements to ease the process for forgiveness of PPP loans to small businesses;
Oppose limits on fee income for credit unions including courtesy pay;
Support limiting burdens of HMDA rule on credit unions;
CFPB should remove unnecessary and unused data points related to HMDA reporting;
Support permanently increasing reporting thresholds for open- and closed-end loans;
Support permanent adoption of CFPBs expired temporary relief of E-SIGN regulation;
Oppose Federal Reserve proposal to decrease debit interchange fee cap (Docket No. R‐1818);
Support for forced arbitration - studies show consumers benefit more often from arbitration than litigation;
Support Credit Union Board Modernization Act (H.R. 582; S. 610);
Support Promoting Access to Capital in Underbanked Communities Act (H.R. 758);
Support Promoting New and Diverse Depository Institutions Act (H.R. 1533; S. 2252);
Support Consumer Financial Protection Commission Act (H.R. 1410);
Support SECURE Notarization Act (H.R. 1059; S. 1212);
Support Prohibiting IRS Financial Surveillance Act (H.R. 1010; S. 453);
Support CBDC Anti-Surveillance State Act (H.R. 1122; H.R. 5403);
Support Data Privacy Act (H.R. 1165);
Support Veterans Member Business Loan Act (S. 539; H.R. 4867);
Support NCUA Central Liquidity Facility Enhancements (S. 544);
Support Neighborhood Homes Investment Act (S. 657);
Support CDFI Bond Guarantee Program Improvement Act (S. 869);
Support Small LENDER Act (H.R. 1806);
Support Transparency in CFPB Cost-Benefit Analysis Act (H.R. 1313);
Support Making the CFPB Accountable to Small Businesses Act (H.R. 1749);
Support Resolution of Disapproval of the CFPBs Section 1071 final rule (H.J.Res. 50; H.J.Res. 66; H.J.Res. 85; S.J.Res. 32)
Support CFPB Transparency and Accountability Reform Act (H.R. 2798);
Support SAFE Banking Act (H.R. 2891; S. 1323);
Support CDFI Fund Transparency Act (H.R. 3161; S. 2674);
Support Building Credit Access for Veterans Act (H.R. 1266);
Support Increasing Financial Regulatory Accountability and Transparency Act (H.R. 3556);
Support Middle Class Borrower Protection Act (H.R. 3564; S. 2296);
Support Digital Dollar Pilot Prevention Act (H.R. 3712);
Oppose Credit Card Competition Act (H.R. 3881; S. 1838);
Support Member Business Loan Expansion Act (H.R. 4868);
Oppose Senate NDAA amendments on interchange (#177; #425);
Support Clarity for Payment Stablecoins Act (H.R. 4766);
Support Senate NDAA amendment on financial literacy (#206);
Support Homes for Every Local Protector, Educator, and Responder (HELPER) Act (H.R. 3170; S. 1514);
Oppose Senate appropriations amendment on interchange (#1161);
Oppose Senate appropriations amendments on interest rate caps (#1225; #1285);
Oppose Capping Credit Card Interest Rates Act (S. 2760);
Support SAFER Banking Act (S. 2860);
Oppose Amendment #117 to H.R. 4664;
Support Amendment #174 to H.R. 4664;
Support provisions of H.R. 4664 to place CFPB under the regular appropriations process and restructure the Bureau to a bipartisan commission;
Support Rectifying UDAAP Act (H.R. 6789);
Support Close the Shadow Banking Loophole Act (S. 3538);
Oppose Predatory Lending Elimination Act (S. 3549);
Comments to NCUA on OMB Number: 3133-NEW supporting streamlined speaker request forms and increased transparency in speaker request process;
Comments to Office of the National Cyber Director on RIN: 0301-AA00 supporting regulatory harmonization and minimizing overlapping or conflicting requirements;
Comments to CFPB on Outline of FCRA Proposals supporting adherence to Congressional intent and reissuance of proposals with more detail and specificity;
Comments to Department of Labor on RIN 1235-AA39 opposing automatic adjustments and encouraging accommodation of smaller credit unions;
Comments to NCUA on proposed 2024-2025 budget opposing unsustainable budget increases and encouraging cost-savings and transparency;
Comments to OMB on OMB-2023-0020 supporting increased transparency on agencies use of artificial intelligence technology;
Comments to NCUA on Docket No. NCUA-2023-0082 supporting simplification of share insurance for trust accounts;
Comments to CFPB on Docket No. CFPB-2023-0052 opposing the proposal and urging CFPB to reduce burden on credit unions and adopt a safe harbor for data providers;
Support FHFA publishing data and analysis related to credit score model validation;
Support regulatory cost-benefit analysis that includes cumulative effects of regulations;
Support extension of comment deadline for Federal Reserve proposal on decreasing the debit interchange fee cap (Docket No. R‐1818);
Support extension of comment deadline for CFPB proposal on personal financial data rights (Docket No. CFPB-2023-0052);
Support CFPB transparency on its use of artificial intelligence technology;
Support NCUA transparency on initiatives to support financial technology innovation;
Support NCUA creating a regulatory sandbox to support financial technology innovation;
Support a delay in the effective date for the CFPBs Section 1071 final rule for all covered entities;
Support NCUA raising commercial loan threshold to $250,000 from current level of $50,000;
Support CFPB convening SBREFA panels for credit card late fee rulemaking;
Oppose Regulation E liability for financial institutions for consumer-authorized transactions;
Support FHFA reopening seasoned bulk transactions window.
17. House(s) of Congress and Federal agencies Check if None
Natl Credit Union Administration (NCUA), Small Business Administration (SBA), Defense - Dept of (DOD), Federal Reserve System, Treasury - Dept of, Securities & Exchange Commission (SEC), Housing & Urban Development - Dept of (HUD), Government Accountability Office (GAO), White House Office, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Federal Housing Finance Agency (FHFA), Consumer Financial Protection Bureau (CFPB), Federal Communications Commission (FCC), Labor - Dept of (DOL), Veterans Affairs - Dept of (VA), Environmental Protection Agency (EPA)
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Dan |
Berger |
|
|
|
Brad |
Thaler |
|
|
|
Chad |
Adams |
|
|
|
Ann |
Kossachev |
|
|
|
Andrew |
Morris |
|
|
|
James |
Akin |
|
|
|
Clark |
Derrington |
|
|
|
Greg |
Mesack |
|
|
|
Allyson |
Gale |
|
|
|
Amber |
Milenkevich |
|
|
|
Amanda |
Smith |
|
LA for Rep. John Carney |
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
Protecting the Credit Union tax exemption
Tax extenders impacting credit unions
Retirement provisions
Direct Reporting
17. House(s) of Congress and Federal agencies Check if None
Internal Revenue Service (IRS), Natl Credit Union Administration (NCUA), Treasury - Dept of, White House Office, U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Federal Trade Commission (FTC), Federal Reserve System
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Dan |
Berger |
|
|
|
Brad |
Thaler |
|
|
|
Chad |
Adams |
|
|
|
Ann |
Kossachev |
|
|
|
Andrew |
Morris |
|
|
|
James |
Akin |
|
|
|
Clark |
Derrington |
|
|
|
Greg |
Mesack |
|
|
|
Allyson |
Gale |
|
|
|
Amber |
Milenkevich |
|
|
|
Amanda |
Smith |
|
LA for Rep. John Carney |
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
| Address |
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| City |
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State |
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Zip Code |
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Country |
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21. Client new principal place of business (if different than line 20)
| City |
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State |
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Zip Code |
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Country |
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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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| 1 |
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3 |
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| 2 |
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4 |
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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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| NAFCU Board of Directors |
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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) |