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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
| Address1 | 901 Community Drive |
Address2 |
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| City | Springfield |
State | IL |
Zip Code | 62703-5184 |
Country | USA |
3. Principal place of business (if different than line 2)
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State |
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Zip Code |
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Country |
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5. Senate ID# 400531588-12
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6. House ID# 411650000
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| TYPE OF REPORT | 8. Year | 2018 |
Q1 (1/1 - 3/31) | Q2 (4/1 - 6/30) | Q3 (7/1 - 9/30) | Q4 (10/1 - 12/31) |
9. Check if this filing amends a previously filed version of this report
| 10. Check if this is a Termination Report | Termination Date |
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11. No Lobbying Issue Activity |
| INCOME OR EXPENSES - YOU MUST complete either Line 12 or Line 13 | |||||||||
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| 12. Lobbying | 13. Organizations | ||||||||
| INCOME relating to lobbying activities for this reporting period was: | EXPENSE relating to lobbying activities for this reporting period were: | ||||||||
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| Provide a good faith estimate, rounded to the nearest $10,000, of all lobbying related income for the client (including all payments to the registrant by any other entity for lobbying activities on behalf of the client). | 14. REPORTING Check box to indicate expense accounting method. See instructions for description of options. | ||||||||
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Method A.
Reporting amounts using LDA definitions only
Method B. Reporting amounts under section 6033(b)(8) of the Internal Revenue Code Method C. Reporting amounts under section 162(e) of the Internal Revenue Code |
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| Signature | Digitally Signed By: David G. Schroeder |
Date | 10/16/2018 8:29:08 PM |
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code BAN
16. Specific lobbying issues
Regulatory relief for community banks in the 115th Congress
Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity
The ICBAs Plan for Prosperity contains the following issue areas and recommendations.
Access to Capital
Restore the original intent of the Basel III rule
Create a more accurate identification of systemic risk
Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement
Relieve community banks from excessive Securities and Exchange Commission rules
Repeal the Collins Amendment for non-SIFIs
Address minority bank capital challenges
Regulatory Relief
Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance
Eliminate arbitrary disparate impact fair lending lawsuits
Ensure the viability of mutual banks through new charter and capital options
Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed
Modernize the Bank Secrecy Act (BSA)
Cut the red tape in small business lending by eliminating burdensome data collection
Target the Volker Rule on a banks individual risk
Preserve access to investment advice for middle-class savers
Mortgage Reform
Create a safe harbor from onerous underwriting standards
Establish relief from burdensome HMDA, escrow and appraisal requirements
Preserve the ability for community banks to continue servicing mortgage loans
Reform the closing process and accompanying paperwork
Bank Oversight and Examination
Strengthen accountability in bank exams and create a workable appeals process
Reform bank oversight and examination to better target risk
Tax Relief
Lower marginal rates needed for individuals, corporations and businesses
Incentivize credit for low- and middle-income customers and American agriculture
Modernize Subchapter S constraints
Create limited liability corporation (LLC) option for community banks
Repeal the estate tax
Update the bank qualified (BQ) bond issuer limitation
Support a five-year loss carryback that encourages lending during economic downturns
Create a tax credit for Bank Secrecy Act (BSA) compliance costs
Agriculture and Rural America
Address arbitrary agricultural loan concentration limits
Institute tax relief for rural lending
(House, Senate, OCC)
Legislation -
H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance (House, OCC)
Senate version of H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance (Senate, OCC)
Letters -
Letter to the U.S. Department of the Treasury regarding U.S. Postal Service reform and banking proposal (U.S. Treasury)
Comment Letter to Department of Housing and Urban Development (HUD) regarding Advance Notice of Proposed Rulemaking: Reconsideration of HUDs Implementation of the Fair Housing Acts Disparate Impact Standard; Docket No. FR-6111-A-01 and RIN 2529-ZA01
Letter to the Federal Deposit Insurance Corporation (FDIC) regarding regulations on brokered deposits (Part 337.6 of the FDIC Rules and Regulations) that impact less than well capitalized banks (FDIC, Federal Reserve, OCC)
Action Alerts -
Action Alert regarding HUDs implementation of the Fair Housing Acts Disparate Impact Standard (HUD)
Miscellaneous -
Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following)
Increasing exemption thresholds for Home Mortgage Disclosure Act (HMDA) reporting;
Granting Qualified Mortgage (QM) status for portfolio mortgage loans at most community banks;
Exempting certain community bank loans from escrow requirements;
Simplifying community bank capital requirements;
Increasing eligibility for a short-form Call Report to restore proportionality to quarterly reporting;
Expanding eligibility for the 18-month regulatory examination cycle;
Easing appraisal requirements to facilitate mortgage credit in local communities;
Exempting most community banks from the Volcker Rule;
Expanding access to the Federal Reserves Small Bank Holding Company Policy Statement to help more community banks build capital;
Improving regulatory treatment of reciprocal deposits and certain municipal securities; and
Section 401 - SIFI thresholds) (House, Senate, OCC)
Bank Secrecy Act (BSA) modernization - Currency Transaction Report (CTR) threshold (House, Senate, OCC)
Tax credit to offset the cost of BSA compliance (House, Senate, OCC)
Small business date collection under the Dodd-Frank Act - Section 1071 (House, Senate, OCC)
Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions in CRA compliance, examination and enforcement (House, Senate, OCC)
Tax credits or deductions for lending to low- and middle-income individuals, businesses, farmers and ranchers (House, Senate, OCC)
The Federal Reserves Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (House, Senate, OCC)
Principals of GSE Reform (House, Senate, OCC)
Agriculture and rural America / rural economic development (House, Senate, OCC)
Expansionist Agenda of Credit Unions (House, Senate, OCC)
Expansionist Agenda of the Farm Credit System (House, Senate, OCC)
Federal Reserve Board nominee Michelle Bowman (Senate)
Cybersecurity and additional regulatory burden on community banks (House)
Federal/State issues in banking the business of marijuana (House)
Home Mortgage Disclosure Act (HMDA) reporting regulatory relief (House)
Beneficial ownership rule regulatory relief (House)
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC), Federal Reserve System, Housing & Urban Development - Dept of (HUD), Treasury - Dept of
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
David |
Schroeder |
|
|
19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code FIN
16. Specific lobbying issues
Regulatory relief for community banks in the 115th Congress
Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity
The ICBAs Plan for Prosperity contains the following issue areas and recommendations.
Access to Capital
Restore the original intent of the Basel III rule
Create a more accurate identification of systemic risk
Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement
Relieve community banks from excessive Securities and Exchange Commission rules
Repeal the Collins Amendment for non-SIFIs
Address minority bank capital challenges
Regulatory Relief
Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance
Eliminate arbitrary disparate impact fair lending lawsuits
Ensure the viability of mutual banks through new charter and capital options
Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed
Modernize the Bank Secrecy Act (BSA)
Cut the red tape in small business lending by eliminating burdensome data collection
Target the Volker Rule on a banks individual risk
Preserve access to investment advice for middle-class savers
Mortgage Reform
Create a safe harbor from onerous underwriting standards
Establish relief from burdensome HMDA, escrow and appraisal requirements
Preserve the ability for community banks to continue servicing mortgage loans
Reform the closing process and accompanying paperwork
Bank Oversight and Examination
Strengthen accountability in bank exams and create a workable appeals process
Reform bank oversight and examination to better target risk
Tax Relief
Lower marginal rates needed for individuals, corporations and businesses
Incentivize credit for low- and middle-income customers and American agriculture
Modernize Subchapter S constraints
Create limited liability corporation (LLC) option for community banks
Repeal the estate tax
Update the bank qualified (BQ) bond issuer limitation
Support a five-year loss carryback that encourages lending during economic downturns
Create a tax credit for Bank Secrecy Act (BSA) compliance costs
Agriculture and Rural America
Address arbitrary agricultural loan concentration limits
Institute tax relief for rural lending
(House, Senate, OCC)
Legislation -
H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance (House, OCC)
Senate version of H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance (Senate, OCC)
Letters -
Letter to the U.S. Department of the Treasury regarding U.S. Postal Service reform and banking proposal (U.S. Treasury)
Comment Letter to Department of Housing and Urban Development (HUD) regarding Advance Notice of Proposed Rulemaking: Reconsideration of HUDs Implementation of the Fair Housing Acts Disparate Impact Standard; Docket No. FR-6111-A-01 and RIN 2529-ZA01
Letter to the Federal Deposit Insurance Corporation (FDIC) regarding regulations on brokered deposits (Part 337.6 of the FDIC Rules and Regulations) that impact less than well capitalized banks (FDIC, Federal Reserve, OCC)
Action Alerts -
Action Alert regarding HUDs implementation of the Fair Housing Acts Disparate Impact Standard (HUD)
Miscellaneous -
Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following)
Increasing exemption thresholds for Home Mortgage Disclosure Act (HMDA) reporting;
Granting Qualified Mortgage (QM) status for portfolio mortgage loans at most community banks;
Exempting certain community bank loans from escrow requirements;
Simplifying community bank capital requirements;
Increasing eligibility for a short-form Call Report to restore proportionality to quarterly reporting;
Expanding eligibility for the 18-month regulatory examination cycle;
Easing appraisal requirements to facilitate mortgage credit in local communities;
Exempting most community banks from the Volcker Rule;
Expanding access to the Federal Reserves Small Bank Holding Company Policy Statement to help more community banks build capital;
Improving regulatory treatment of reciprocal deposits and certain municipal securities; and
Section 401 - SIFI thresholds) (House, Senate, OCC)
Bank Secrecy Act (BSA) modernization - Currency Transaction Report (CTR) threshold (House, Senate, OCC)
Tax credit to offset the cost of BSA compliance (House, Senate, OCC)
Small business data collection under the Dodd-Frank Act - Section 1071 (House, Senate, OCC)
Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions in CRA compliance, examination and enforcement (House, Senate, OCC)
Tax credits or deductions for lending to low- and middle-income individuals, businesses, farmers and ranchers (House, Senate, OCC)
The Federal Reserves Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (House, Senate, OCC)
Principals of GSE Reform (House, Senate, OCC)
Agriculture and rural America / rural economic development (House, Senate, OCC)
Expansionist Agenda of Credit Unions (House, Senate, OCC)
Expansionist Agenda of the Farm Credit System (House, Senate, OCC)
Federal Reserve Board nominee Michelle Bowman (Senate)
Cybersecurity and additional regulatory burden on community banks (House)
Federal/State issues in banking the business of marijuana (House)
Home Mortgage Disclosure Act (HMDA) reporting regulatory relief (House)
Beneficial ownership rule regulatory relief (House)
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC), Federal Reserve System, Housing & Urban Development - Dept of (HUD), Treasury - Dept of
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
David |
Schroeder |
|
|
19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code AGR
16. Specific lobbying issues
Regulatory relief for community banks in the 115th Congress
Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity
The ICBAs Plan for Prosperity contains the following issue areas and recommendations.
Agriculture and Rural America
Address arbitrary agricultural loan concentration limits
Institute tax relief for rural lending
(House, Senate, OCC)
Legislation -
H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance (House, OCC)
Senate version of H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance (Senate, OCC)
Letters -
Letter to the U.S. Department of the Treasury regarding U.S. Postal Service reform and banking proposal (U.S. Treasury)
Miscellaneous -
Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following)
Increasing exemption thresholds for Home Mortgage Disclosure Act (HMDA) reporting;
Granting Qualified Mortgage (QM) status for portfolio mortgage loans at most community banks;
Exempting certain community bank loans from escrow requirements;
Simplifying community bank capital requirements;
Increasing eligibility for a short-form Call Report to restore proportionality to quarterly reporting;
Expanding eligibility for the 18-month regulatory examination cycle;
Easing appraisal requirements to facilitate mortgage credit in local communities;
Exempting most community banks from the Volcker Rule;
Expanding access to the Federal Reserves Small Bank Holding Company Policy Statement to help more community banks build capital;
Improving regulatory treatment of reciprocal deposits and certain municipal securities; and
Section 401 - SIFI thresholds) (House, Senate, OCC)
Expansionist Agenda of the Farm Credit System (House, Senate, OCC)
Cybersecurity and additional regulatory burden on community banks (House)
Small business data collection under the Dodd-Frank Act - Section 1071 (House, Senate, OCC)
Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions in CRA compliance, examination and enforcement (House, Senate, OCC)
Tax credits or deductions for lending to low- and middle-income individuals, businesses, farmers and ranchers (House, Senate, OCC)
The Federal Reserves Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (House, Senate, OCC)
Principals of GSE Reform (House, Senate, OCC)
Agriculture and rural America / rural economic development (House, Senate, OCC)
Federal/State issues in banking the business of marijuana (House)
Home Mortgage Disclosure Act (HMDA) reporting regulatory relief (House)
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, 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
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
David |
Schroeder |
|
|
19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code CSP
16. Specific lobbying issues
Regulatory relief for community banks in the 115th Congress
Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity
The ICBAs Plan for Prosperity contains the following issue areas and recommendations.
Regulatory Relief
Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance
Eliminate arbitrary disparate impact fair lending lawsuits
Ensure the viability of mutual banks through new charter and capital options
Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed
Modernize the Bank Secrecy Act (BSA)
Cut the red tape in small business lending by eliminating burdensome data collection
Target the Volker Rule on a banks individual risk
Preserve access to investment advice for middle-class savers
Mortgage Reform
Create a safe harbor from onerous underwriting standards
Establish relief from burdensome HMDA, escrow and appraisal requirements
Preserve the ability for community banks to continue servicing mortgage loans
Reform the closing process and accompanying paperwork
Tax Relief
Lower marginal rates needed for individuals, corporations and businesses
Incentivize credit for low- and middle-income customers and American agriculture
Modernize Subchapter S constraints
Create limited liability corporation (LLC) option for community banks
Repeal the estate tax
Update the bank qualified (BQ) bond issuer limitation
Support a five-year loss carryback that encourages lending during economic downturns
Create a tax credit for Bank Secrecy Act (BSA) compliance costs
(House, Senate, OCC)
Letters -
Letter to the U.S. Department of the Treasury regarding U.S. Postal Service reform and banking proposal (U.S. Treasury)
Comment Letter to Department of Housing and Urban Development (HUD) regarding Advance Notice of Proposed Rulemaking: Reconsideration of HUDs Implementation of the Fair Housing Acts Disparate Impact Standard; Docket No. FR-6111-A-01 and RIN 2529-ZA01
Action Alerts -
Action Alert regarding HUDs implementation of the Fair Housing Acts Disparate Impact Standard (HUD)
Miscellaneous -
Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following)
Increasing exemption thresholds for Home Mortgage Disclosure Act (HMDA) reporting;
Granting Qualified Mortgage (QM) status for portfolio mortgage loans at most community banks;
Exempting certain community bank loans from escrow requirements;
Simplifying community bank capital requirements;
Increasing eligibility for a short-form Call Report to restore proportionality to quarterly reporting;
Expanding eligibility for the 18-month regulatory examination cycle;
Easing appraisal requirements to facilitate mortgage credit in local communities;
Exempting most community banks from the Volcker Rule;
Expanding access to the Federal Reserves Small Bank Holding Company Policy Statement to help more community banks build capital;
Improving regulatory treatment of reciprocal deposits and certain municipal securities; and
Section 401 - SIFI thresholds) (House, Senate, OCC)
Bank Secrecy Act (BSA) modernization - Currency Transaction Report (CTR) threshold (House, Senate, OCC)
Small business data collection under the Dodd-Frank Act - Section 1071 (House, Senate, OCC)
Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions in CRA compliance, examination and enforcement (House, Senate, OCC)
Tax credits or deductions for lending to low- and middle-income individuals, businesses, farmers and ranchers (House, Senate, OCC)
The Federal Reserves Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (House, Senate, OCC)
Principals of GSE Reform (House, Senate, OCC)
Agriculture and rural America / rural economic development (House, Senate, OCC)
Expansionist Agenda of Credit Unions (House, Senate, OCC)
Cybersecurity and additional regulatory burden on community banks (House)
Home Mortgage Disclosure Act (HMDA) reporting regulatory relief (House)
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Office of the Comptroller of the Currency (OCC), Housing & Urban Development - Dept of (HUD), Treasury - Dept of
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
David |
Schroeder |
|
|
19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code SMB
16. Specific lobbying issues
Regulatory relief for community banks in the 115th Congress
Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity
The ICBAs Plan for Prosperity contains the following issue areas and recommendations.
Access to Capital
Restore the original intent of the Basel III rule
Create a more accurate identification of systemic risk
Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement
Relieve community banks from excessive Securities and Exchange Commission rules
Repeal the Collins Amendment for non-SIFIs
Address minority bank capital challenges
Regulatory Relief
Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance
Eliminate arbitrary disparate impact fair lending lawsuits
Ensure the viability of mutual banks through new charter and capital options
Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed
Modernize the Bank Secrecy Act (BSA)
Cut the red tape in small business lending by eliminating burdensome data collection
Target the Volker Rule on a banks individual risk
Preserve access to investment advice for middle-class savers
Tax Relief
Lower marginal rates needed for individuals, corporations and businesses
Incentivize credit for low- and middle-income customers and American agriculture
Modernize Subchapter S constraints
Create limited liability corporation (LLC) option for community banks
Repeal the estate tax
Update the bank qualified (BQ) bond issuer limitation
Support a five-year loss carryback that encourages lending during economic downturns
Create a tax credit for Bank Secrecy Act (BSA) compliance costs
Agriculture and Rural America
Address arbitrary agricultural loan concentration limits
Institute tax relief for rural lending
(House, Senate, OCC)
Legislation -
H.R. 2 - Agricultural Improvement Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance (House, OCC)
Senate version of H.R. 2 - Agriculture and Nutrition Act of 2018 (The Farm Bill) (sections pertaining to the reduction or limitation of participation in crop insurance, increased cost of crop insurance during economic downturns, and harming private sector delivery of crop insurance (Senate, OCC)
Miscellaneous -
Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following)
Increasing exemption thresholds for Home Mortgage Disclosure Act (HMDA) reporting;
Granting Qualified Mortgage (QM) status for portfolio mortgage loans at most community banks;
Exempting certain community bank loans from escrow requirements;
Simplifying community bank capital requirements;
Increasing eligibility for a short-form Call Report to restore proportionality to quarterly reporting;
Expanding eligibility for the 18-month regulatory examination cycle;
Easing appraisal requirements to facilitate mortgage credit in local communities;
Exempting most community banks from the Volcker Rule;
Expanding access to the Federal Reserves Small Bank Holding Company Policy Statement to help more community banks build capital;
Improving regulatory treatment of reciprocal deposits and certain municipal securities; and
Section 401 - SIFI thresholds) (House, Senate, OCC)
Bank Secrecy Act (BSA) modernization - Currency Transaction Report (CTR) threshold (House, Senate, OCC)
Small business data collection under the Dodd-Frank Act - Section 1071 (House, Senate, OCC)
Modernization of the Community Reinvestment Act (CRA) including examination thresholds and including credit unions in CRA compliance, examination and enforcement (House, Senate, OCC)
Tax credits or deductions for lending to low- and middle-income individuals, businesses, farmers and ranchers (House, Senate, OCC)
The Federal Reserves Payments System Improvements initiative specifically regarding the Feds role in these improvements and maintaining a system that is progressive, competitive and secure, with open access to community banks regardless of size, charter type and location (House, Senate, OCC)
Agriculture and rural America / rural economic development (House, Senate, OCC)
Expansionist Agenda of Credit Unions (House, Senate, OCC)
Expansionist Agenda of the Farm Credit System (House, Senate, OCC)
Cybersecurity and additional regulatory burden on community banks (House)
Federal/State issues in banking the business of marijuana (House)
Beneficial ownership rule regulatory relief (House)
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Office of the Comptroller of the Currency (OCC)
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
David |
Schroeder |
|
|
19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code TAX
16. Specific lobbying issues
Regulatory relief for community banks in the 115th Congress
Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity
The ICBAs Plan for Prosperity contains the following issue areas and recommendations.
Tax Relief
Lower marginal rates needed for individuals, corporations and businesses
Incentivize credit for low- and middle-income customers and American agriculture
Modernize Subchapter S constraints
Create limited liability corporation (LLC) option for community banks
Repeal the estate tax
Update the bank qualified (BQ) bond issuer limitation
Support a five-year loss carryback that encourages lending during economic downturns
Create a tax credit for Bank Secrecy Act (BSA) compliance costs
Agriculture and Rural America
Address arbitrary agricultural loan concentration limits
Institute tax relief for rural lending
(House, Senate, OCC)
Miscellaneous -
Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following)
Increasing exemption thresholds for Home Mortgage Disclosure Act (HMDA) reporting;
Granting Qualified Mortgage (QM) status for portfolio mortgage loans at most community banks;
Exempting certain community bank loans from escrow requirements;
Simplifying community bank capital requirements;
Increasing eligibility for a short-form Call Report to restore proportionality to quarterly reporting;
Expanding eligibility for the 18-month regulatory examination cycle;
Easing appraisal requirements to facilitate mortgage credit in local communities;
Exempting most community banks from the Volcker Rule;
Expanding access to the Federal Reserves Small Bank Holding Company Policy Statement to help more community banks build capital;
Improving regulatory treatment of reciprocal deposits and certain municipal securities; and
Section 401 - SIFI thresholds) (House, Senate, OCC)
Tax credit to offset the cost of BSA compliance (House, Senate, OCC)
Tax credits or deductions for lending to low- and middle-income individuals, businesses, farmers and ranchers (House, Senate, OCC)
Expansionist Agenda of Credit Unions (House, Senate, OCC)
Expansionist Agenda of the Farm Credit System (House, Senate, OCC)
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Office of the Comptroller of the Currency (OCC)
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
David |
Schroeder |
|
|
19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code ECN
16. Specific lobbying issues
Miscellaneous -
Implementation of S. 2155 - The Economic Growth, Regulatory Relief and Consumer Protection Act (All sections but in particular the following)
Increasing exemption thresholds for Home Mortgage Disclosure Act (HMDA) reporting;
Granting Qualified Mortgage (QM) status for portfolio mortgage loans at most community banks;
Exempting certain community bank loans from escrow requirements;
Simplifying community bank capital requirements;
Increasing eligibility for a short-form Call Report to restore proportionality to quarterly reporting;
Expanding eligibility for the 18-month regulatory examination cycle;
Easing appraisal requirements to facilitate mortgage credit in local communities;
Exempting most community banks from the Volcker Rule;
Expanding access to the Federal Reserves Small Bank Holding Company Policy Statement to help more community banks build capital;
Improving regulatory treatment of reciprocal deposits and certain municipal securities; and
Section 401 - SIFI thresholds) (House, Senate, OCC)
Agriculture and rural America / rural economic development (House, Senate, OCC)
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Office of the Comptroller of the Currency (OCC)
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
David |
Schroeder |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
Information Update Page - Complete ONLY where registration information has changed.
20. Client new address
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21. Client new principal place of business (if different than line 20)
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22. New General description of client’s business or activities
LOBBYIST UPDATE
23. Name of each previously reported individual who is no longer expected to act as a lobbyist for the client
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ISSUE UPDATE
24. General lobbying issue that no longer pertains
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AFFILIATED ORGANIZATIONS
25. Add the following affiliated organization(s)
Internet Address:
| Name | Address |
Principal Place of Business (city and state or country) |
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26. Name of each previously reported organization that is no longer affiliated with the registrant or client
| 1 | 2 | 3 |
FOREIGN ENTITIES
27. Add the following foreign entities:
| Name | Address |
Principal place of business (city and state or country) |
Amount of contribution for lobbying activities | Ownership percentage in client | ||||||||||
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28. Name of each previously reported foreign entity that no longer owns, or controls, or is affiliated with the registrant, client or affiliated organization
| 1 | 3 | 5 |
| 2 | 4 | 6 |