Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page

9. Check if this filing amends a previously filed version of this report

LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code BAN

16. Specific lobbying issues

CBAI 2022 Federal Policy Priorities -

Community Bank Response to the COVID-19 Pandemic

COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function.

Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress

CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country.

Additional Meaningful Regulatory Relief for Community Banks

Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors.

Community Bank Position on Credit Unions and Their Expanded Powers

Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve.

Community Bank Position on the Farm Credit System and its Expanded Powers

The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks.

Closing the Industrial Loan Company (ILC) Regulatory Loophole

ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve, and must be closed.

Federal Reserves Role in Payments System Improvement (FedNow Service)

A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis.

Modernizing the Community Reinvestment Act (CRA)

The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA.

Safe Harbor for Banking Cannabis-Related Businesses

Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted.

De Novo Community Bank Formation, the Dual Banking System and Charter Choice

Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession.

The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues.

Sound Principles for GSE Reform

The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress.

Federal Home Loan Banks

Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members.

Agriculture and Rural America

A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery.

Enhanced Data, Cyber and Payment Card Security (Data Security)

Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards.

Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks

Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model.

In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies.

The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers.

Community Bank Positions on New and Emerging Issues -

Leadership for Bank Regulatory Agencies (Administration, Congress, and the Agencies)

Recent nominees have held extreme views on the banking system and financial services and their nominations have increasingly caused unproductive political wrangling. Nominees should be qualified, hold reasonable positions, be willing to work collegially and cooperatively with colleagues and counterparts, serve the best interests of the banking and financial system and economy, and clearly understand the vital importance of and support community banks.

Fintechs and Innovation in Financial Services (Congress and the Agencies)

Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements.

Special Purpose National Banks (SPNBs) (OCC)

SPNBs, raise many concerns. They cannot have the advantages of a bank charter with limited requirements, regulations, and liability.

Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies)

The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks.

IRS Reporting Plan (Administration, Congress and Treasury)

The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses.

SBA Direct Lending (Congress)

Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss.

Financial Inclusion (Congress and the Agencies)

CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked.

Postal Banking - Congress

Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks.

Public Banking (Congress)

Public banking (i.e., publicly-owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks.

Current Expected Credit Loss Model (CECL) (FASB and the Agencies)

Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks.

Customer Data Sharing (CFPB)

Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers.

Small Business Data Collection (CFPB)

Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements fall disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking.

Nonsufficient Funds (Overdraft) Policies and Practices (OCC and the CFPB)

CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include including returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement.

Reporting Beneficial Ownership Information (FinCEN)

Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously.

Financial Transaction Tax (Congress)

Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance.

Climate Risks (Administration, Congress, and the Agencies)

CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks.

Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporating material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary.

Bank Merger Activity (Congress and the Agencies)

New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected.

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

The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized.

(House and Senate, FDIC, OCC)

Legislation and Regulation -

H.R. 1996 - The SAFE Banking Act in the Senate (all sections) which permits the banking of cannabis related businesses in states where it is legal (Senate)

HR 4277 - the Overdraft Protection Act of 2021(all sections) which limits banks ability to charge overdraft fees (House)

H.R. 5912 - Close the ILC Loophole Act (all sections) which is legislation to reform the regulation of industrial loan companies (ILCs) and their parent companies to provide for consolidated federal supervision (House)

Letters -

Comment Letter to the SEC regarding Enhancement and Standardization of Climate-Related Disclosures for Investors - 87 Fed. Reg. 21,334 (April 11, 2022) (SEC)

Comment Letter to the Federal Reserve, FDIC and the OCC regarding Joint Notice of Proposed Rulemaking; Request for Comment on Community Reinvestment Act - Office of Comptroller of the Currency, Docker ID OCC-2022-0002 and RIN 1557-AF15; Federal Deposit Insurance Corporation, RIN 3064-AF81; Federal Reserve, Docket No. R-1769 and RIN 7100-AG-29 (Federal Reserve, FDIC, OCC and House)

Comment Letter to the Department of the Treasury regarding Request for Comments - Ensuring Responsible Development of Digital Assets (Treasury)

Comment Letter to the FDIC regarding Notice of Public Rulemaking - Assessments, Revised Deposit Insurance Assessment Rates - RIN 3064-AF83 (FDIC)

Action Alerts -

Action Alert regarding: FDICs Notice of Proposed Rulemaking to Increase Deposit Insurance Assessments (FDIC)

Miscellaneous -

Debit Interchange (Reg II) regulations (Senate)

Proposed stablecoin legislation (House)

Check fraud and return items/recovery (Federal Reserve, FDIC and OCC)

Overdraft and NSF fees in general and particularly representment (Federal Reserve, FDIC and OCC)

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

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), Federal Reserve System, Federal Deposit Insurance Corporation (FDIC), Treasury - Dept of, Securities & Exchange Commission (SEC)

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

​

LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code FIN

16. Specific lobbying issues

CBAI 2022 Federal Policy Priorities -

Community Bank Response to the COVID-19 Pandemic

COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function.

Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress

CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country.

Additional Meaningful Regulatory Relief for Community Banks

Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors.

Community Bank Position on Credit Unions and Their Expanded Powers

Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve.

Community Bank Position on the Farm Credit System and its Expanded Powers

The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks.

Closing the Industrial Loan Company (ILC) Regulatory Loophole

ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve, and must be closed.

Federal Reserves Role in Payments System Improvement (FedNow Service)

A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis.

Modernizing the Community Reinvestment Act (CRA)

The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA.

Safe Harbor for Banking Cannabis-Related Businesses

Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted.

De Novo Community Bank Formation, the Dual Banking System and Charter Choice

Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession.

The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues.

Sound Principles for GSE Reform

The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress.

Federal Home Loan Banks

Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members.

Agriculture and Rural America

A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery.

Enhanced Data, Cyber and Payment Card Security (Data Security)

Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards.

Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks

Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model.

In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies.

The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers.

Community Bank Positions on New and Emerging Issues -

Leadership for Bank Regulatory Agencies (Administration, Congress, and the Agencies)

Recent nominees have held extreme views on the banking system and financial services and their nominations have increasingly caused unproductive political wrangling. Nominees should be qualified, hold reasonable positions, be willing to work collegially and cooperatively with colleagues and counterparts, serve the best interests of the banking and financial system and economy, and clearly understand the vital importance of and support community banks.

Fintechs and Innovation in Financial Services (Congress and the Agencies)

Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements.

Special Purpose National Banks (SPNBs) (OCC)

SPNBs, raise many concerns. They cannot have the advantages of a bank charter with limited requirements, regulations, and liability.

Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies)

The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks.

IRS Reporting Plan (Administration, Congress and Treasury)

The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses.

SBA Direct Lending (Congress)

Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss.

Financial Inclusion (Congress and the Agencies)

CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked.

Postal Banking - Congress

Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks.

Public Banking (Congress)

Public banking (i.e., publicly-owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks.

Current Expected Credit Loss Model (CECL) (FASB and the Agencies)

Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks.

Customer Data Sharing (CFPB)

Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers.

Small Business Data Collection (CFPB)

Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements fall disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking.

Nonsufficient Funds (Overdraft) Policies and Practices (OCC and the CFPB)

CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include including returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement.

Reporting Beneficial Ownership Information (FinCEN)

Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously.

Financial Transaction Tax (Congress)

Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance.

Climate Risks (Administration, Congress, and the Agencies)

CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks.

Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporating material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary.

Bank Merger Activity (Congress and the Agencies)

New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected.

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

The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized.

(House and Senate, FDIC, OCC)

Legislation and Regulation -

H.R. 1996 - The SAFE Banking Act in the Senate (all sections) which permits the banking of cannabis related businesses in states where it is legal (Senate)

HR 4277 - the Overdraft Protection Act of 2021(all sections) which limits banks ability to charge overdraft fees (House)

H.R. 5912 - Close the ILC Loophole Act (all sections) which is legislation to reform the regulation of industrial loan companies (ILCs) and their parent companies to provide for consolidated federal supervision (House)

Letters -

Comment Letter to the SEC regarding Enhancement and Standardization of Climate-Related Disclosures for Investors - 87 Fed. Reg. 21,334 (April 11, 2022) (SEC)

Comment Letter to the Federal Reserve, FDIC and the OCC regarding Joint Notice of Proposed Rulemaking; Request for Comment on Community Reinvestment Act - Office of Comptroller of the Currency, Docker ID OCC-2022-0002 and RIN 1557-AF15; Federal Deposit Insurance Corporation, RIN 3064-AF81; Federal Reserve, Docket No. R-1769 and RIN 7100-AG-29 (Federal Reserve, FDIC, OCC and House)

Comment Letter to the Department of the Treasury regarding Request for Comments - Ensuring Responsible Development of Digital Assets (Treasury)

Comment Letter to the FDIC regarding Notice of Public Rulemaking - Assessments, Revised Deposit Insurance Assessment Rates - RIN 3064-AF83 (FDIC)

Action Alerts -

Action Alert regarding: FDICs Notice of Proposed Rulemaking to Increase Deposit Insurance Assessments (FDIC)

Miscellaneous -

Debit Interchange (Reg II) regulations (Senate)

Proposed stablecoin legislation (House)

Check fraud and return items/recovery (Federal Reserve, FDIC and OCC)

Overdraft and NSF fees in general and particularly representment (Federal Reserve, FDIC and OCC)

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

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), Federal Reserve System, Federal Deposit Insurance Corporation (FDIC), Treasury - Dept of, Securities & Exchange Commission (SEC)

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

​

LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code AGR

16. Specific lobbying issues

CBAI 2022 Federal Policy Priorities -

Community Bank Response to the COVID-19 Pandemic

COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function.

Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress

CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country.

Additional Meaningful Regulatory Relief for Community Banks

Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors.

Community Bank Position on Credit Unions and Their Expanded Powers

Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve.

Community Bank Position on the Farm Credit System and its Expanded Powers

The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks.

Federal Reserves Role in Payments System Improvement (FedNow Service)

A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis.

Modernizing the Community Reinvestment Act (CRA)

The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA.

Safe Harbor for Banking Cannabis-Related Businesses

Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted.

Sound Principles for GSE Reform

The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress.

Federal Home Loan Banks

Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members.

Agriculture and Rural America

A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery.

Enhanced Data, Cyber and Payment Card Security (Data Security)

Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards.

Community Bank Positions on New and Emerging Issues -

Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies)

The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks.

IRS Reporting Plan (Administration, Congress and Treasury)

The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses.

Customer Data Sharing (CFPB)

Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers.

Small Business Data Collection (CFPB)

Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements fall disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking.

Reporting Beneficial Ownership Information (FinCEN)

Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously.

Financial Transaction Tax (Congress)

Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance.

Climate Risks (Administration, Congress, and the Agencies)

CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks.

Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporating material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary.

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

The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized.

(House and Senate, FDIC and OCC)

Legislation and Regulation -

H.R. 1996 - The SAFE Banking Act in the Senate (all sections) which permits the banking of cannabis related businesses in states where it is legal (Senate)

Letters -

Comment Letter to the Federal Reserve, FDIC and the OCC regarding Joint Notice of Proposed Rulemaking; Request for Comment on Community Reinvestment Act - Office of Comptroller of the Currency, Docker ID OCC-2022-0002 and RIN 1557-AF15; Federal Deposit Insurance Corporation, RIN 3064-AF81; Federal Reserve, Docket No. R-1769 and RIN 7100-AG-29 (Federal Reserve, FDIC,OCC and House)

Action Alerts -

None

Miscellaneous -

None

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

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Federal Reserve System, Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC)

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

​

LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code CSP

16. Specific lobbying issues

CBAI 2022 Federal Policy Priorities -

Community Bank Response to the COVID-19 Pandemic

COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function.

Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress

CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country.

Additional Meaningful Regulatory Relief for Community Banks

Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors.

Community Bank Position on Credit Unions and Their Expanded Powers

Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve.

Closing the Industrial Loan Company (ILC) Regulatory Loophole

ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve, and must be closed.

Federal Reserves Role in Payments System Improvement (FedNow Service)

A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis.

Modernizing the Community Reinvestment Act (CRA)

The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA.

Safe Harbor for Banking Cannabis-Related Businesses

Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted.

Sound Principles for GSE Reform

The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress.

Federal Home Loan Banks

Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members.

Enhanced Data, Cyber and Payment Card Security (Data Security)

Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards.

Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks

Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model.

In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies.

The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers.

Community Bank Positions on New and Emerging Issues -

Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies)

The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks.

IRS Reporting Plan (Administration, Congress and Treasury)

The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses.

Financial Inclusion (Congress and the Agencies)

CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked.

Postal Banking (Congress)

Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks.

Public Banking (Congress)

Public banking (i.e., publicly-owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks.

Customer Data Sharing (CFPB)

Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers.

Nonsufficient Funds (Overdraft) Policies and Practices (OCC and the CFPB)

CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include including returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement.

Financial Transaction Tax (Congress)

Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance.

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

The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized.

(House and Senate, FDIC, OCC)

Legislation and Regulations -

H.R. 1996 - The SAFE Banking Act in the Senate (all sections) which permits the banking of cannabis related businesses in states where it is legal (Senate)

HR 4277 - the Overdraft Protection Act of 2021(all sections) which limits banks ability to charge overdraft fees (House)

Letters -

Comment Letter to the Federal Reserve, FDIC and the OCC regarding Joint Notice of Proposed Rulemaking; Request for Comment on Community Reinvestment Act - Office of Comptroller of the Currency, Docker ID OCC-2022-0002 and RIN 1557-AF15; Federal Deposit Insurance Corporation, RIN 3064-AF81; Federal Reserve, Docket No. R-1769 and RIN 7100-AG-29 (Federal Reserve, FDIC, OCC and House)

Comment Letter to the Department of the Treasury regarding Request for Comments - Ensuring Responsible Development of Digital Assets (Treasury)

Action Alerts -

None

Miscellaneous -

Debit Interchange (Reg II) regulations (Senate)

Proposed stablecoin legislation (House)

Check fraud and return items/recovery (Federal Reserve, FDIC and OCC)

Overdraft and NSF fees in general and particularly representment (Federal Reserve, FDIC and OCC)

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

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Federal Reserve System, Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC), Treasury - Dept of

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

​

LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code SMB

16. Specific lobbying issues

CBAI 2022 Federal Policy Priorities -

Community Bank Response to the COVID-19 Pandemic

COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function.

Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress

CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country.

Additional Meaningful Regulatory Relief for Community Banks

Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors.

Community Bank Position on Credit Unions and Their Expanded Powers

Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve.

Community Bank Position on the Farm Credit System and its Expanded Powers

The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks.

Federal Reserves Role in Payments System Improvement (FedNow Service)

A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis.

Modernizing the Community Reinvestment Act (CRA)

The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA.

Safe Harbor for Banking Cannabis-Related Businesses

Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted.

Agriculture and Rural America

A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery.

Enhanced Data, Cyber and Payment Card Security (Data Security)

Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards.

Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks

Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model.

In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies.

The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers.

Community Bank Positions on New and Emerging Issues -

Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies)

The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e., disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks.

IRS Reporting Plan (Administration, Congress and Treasury)

The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses.

SBA Direct Lending (Congress)

Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss.

Customer Data Sharing (CFPB)

Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers.

Small Business Data Collection (CFPB)

Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements fall disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking.

Reporting Beneficial Ownership Information (FinCEN)

Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously.

Financial Transaction Tax (Congress)

Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance.

Climate Risks (Administration, Congress, and the Agencies)

CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks.

Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporating material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary.

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

The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized.

(House and Senate, FDIC, OCC)

Legislation and Regulation -

H.R. 1996 - The SAFE Banking Act in the Senate (all sections) which permits the banking of cannabis related businesses in states where it is legal (Senate)

Letters -

Comment Letter to the Federal Reserve, FDIC and the OCC regarding Joint Notice of Proposed Rulemaking; Request for Comment on Community Reinvestment Act - Office of Comptroller of the Currency, Docker ID OCC-2022-0002 and RIN 1557-AF15; Federal Deposit Insurance Corporation, RIN 3064-AF81; Federal Reserve, Docket No. R-1769 and RIN 7100-AG-29 (Federal Reserve, FDIC, OCC and House)


Action Alerts -

None


Miscellaneous -

Debit Interchange (Reg II) regulations (Senate)

Proposed stablecoin legislation (House)

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

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Federal Reserve System, Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC)

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

​

LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code TAX

16. Specific lobbying issues

CBAI 2022 Federal Policy Priorities -

Community Bank Response to the COVID-19 Pandemic

COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function.

Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress

CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country.

Additional Meaningful Regulatory Relief for Community Banks

Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors.

Community Bank Position on Credit Unions and Their Expanded Powers

Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve.

Community Bank Position on the Farm Credit System and its Expanded Powers

The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks.

Modernizing the Community Reinvestment Act (CRA)

The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA.

Community Bank Positions on New and Emerging Issues -

Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies)

The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks.

IRS Reporting Plan (Administration, Congress and Treasury)

The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses.

Financial Transaction Tax (Congress)

Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance.

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

The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized.

(House and Senate, FDIC, OCC)

Legislation and Regulation -

None

Letters -

Comment Letter to the Federal Reserve, FDIC and the OCC regarding Joint Notice of Proposed Rulemaking; Request for Comment on Community Reinvestment Act - Office of Comptroller of the Currency, Docker ID OCC-2022-0002 and RIN 1557-AF15; Federal Deposit Insurance Corporation, RIN 3064-AF81; Federal Reserve, Docket No. R-1769 and RIN 7100-AG-29 (Federal Reserve, FDIC, OCC and House)


Action Alerts -

None

Miscellaneous -

None

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

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Federal Reserve System, Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC)

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

​

LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code ECN

16. Specific lobbying issues

CBAI 2022 Federal Policy Priorities -

Community Bank Response to the COVID-19 Pandemic

COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function.

Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress

CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country.

Additional Meaningful Regulatory Relief for Community Banks

Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors.

Community Bank Position on Credit Unions and Their Expanded Powers

Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve.

Community Bank Position on the Farm Credit System and its Expanded Powers

The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks.

Federal Reserves Role in Payments System Improvement (FedNow Service)

A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis.

Modernizing the Community Reinvestment Act (CRA)

The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA.

Agriculture and Rural America

A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery.

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

The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized.

(House and Senate, FDIC, OCC)

Legislation and Regulation -

Comment Letter to the Federal Reserve, FDIC and the OCC regarding Joint Notice of Proposed Rulemaking; Request for Comment on Community Reinvestment Act - Office of Comptroller of the Currency, Docker ID OCC-2022-0002 and RIN 1557-AF15; Federal Deposit Insurance Corporation, RIN 3064-AF81; Federal Reserve, Docket No. R-1769 and RIN 7100-AG-29 (Federal Reserve, FDIC, OCC and House)

Letters -

None

Action Alerts -

None

Miscellaneous -

None

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

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Federal Reserve System, Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC)

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

​

Information Update Page - Complete ONLY where registration information has changed.

20. Client new address

21. Client new principal place of business (if different than line 20)

22. New General description of client’s business or activities

LOBBYIST UPDATE

23. Name of each previously reported individual who is no longer expected to act as a lobbyist for the client

ISSUE UPDATE

24. General lobbying issue that no longer pertains

AFFILIATED ORGANIZATIONS

25. Add the following affiliated organization(s)

Internet Address:

26. Name of each previously reported organization that is no longer affiliated with the registrant or client

FOREIGN ENTITIES

27. Add the following foreign entities:

28. Name of each previously reported foreign entity that no longer owns, or controls, or is affiliated with the registrant, client or affiliated organization

CONVICTIONS DISCLOSURE

29. Have any of the lobbyists listed on this report been convicted in a Federal or State Court of an offense involving bribery, extortion, embezzlement, an illegal kickback, tax evasion, fraud, a conflict of interest, making a false statement, perjury, or money laundering?
No Yes