|
LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
| Address1 | 901 Community Drive |
Address2 |
|
| City | Springfield |
State | IL |
Zip Code | 62703-5184 |
Country | USA |
3. Principal place of business (if different than line 2)
| City |
|
State |
|
Zip Code |
|
Country |
|
|
5. Senate ID# 400531588-12
|
||||||||
|
6. House ID# 411650000
|
||||||||
| TYPE OF REPORT | 8. Year | 2020 |
Q1 (1/1 - 3/31) | Q2 (4/1 - 6/30) | Q3 (7/1 - 9/30) | Q4 (10/1 - 12/31) |
9. Check if this filing amends a previously filed version of this report
| 10. Check if this is a Termination Report | Termination Date |
|
11. No Lobbying Issue Activity |
| INCOME OR EXPENSES - YOU MUST complete either Line 12 or Line 13 | |||||||||
|---|---|---|---|---|---|---|---|---|---|
| 12. Lobbying | 13. Organizations | ||||||||
| INCOME relating to lobbying activities for this reporting period was: | EXPENSE relating to lobbying activities for this reporting period were: | ||||||||
|
|
||||||||
|
|
||||||||
| 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. | ||||||||
|
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 |
|||||||||
| Signature | Digitally Signed By: David G. Schroeder |
Date | 7/10/2020 11:51:25 AM |
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code BAN
16. Specific lobbying issues
Legislation and Regulation -
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
interest rate below break-even,
short PPP loan terms,
restricted use of PPP loan proceeds, and
lender liability, and
a PPP related liquidity facility
(Treasury, SBA, House, Senate and Federal Reserve)
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
lender participation in the PPP,
general availability of SBA forms,
access to the SBAs portal,
obtaining log-in credentials,
SBA forms to obtain approval to become certified,
SBA website list of active SBA lenders,
SBA website list of PPP lenders,
SBA call center access,
late release of rules prior to the PPP going live,
confusion surrounding the guaranteed portion of the PPP loans,
bank board members not eligible to apply for PPP loans at their bank,
PPP related liquidity facility,
access to the SBA for answers to questions about the PPP,
conflicting messaging from the SBA, and
consistent need for additional guidance from the SBA and Treasury on various aspects of the PPP
(House and Senate)
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
SBA technology supporting the PPP including delays in accessing E-Tran and the Lender Gateway,
additional funding for (replenishing) the PPP,
allocation of 25% of future PPP funds for banks under $50 billion in assets, and
the creation of a Federal Reserve facility to support lending by providing term financing backed by PPP loans
(Treasury, SBA, Federal Reserve, House and Senate)
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
allocation of 25% of future PPP funds for banks under $50 billion in assets,
more workable loan terms - interest rates below funding costs,
more flexible timing for loan disbursements
expanding the program to meet non-payroll expenses,
lender safe harbor, and
suspending the beneficial ownership rule for non-current customers
(House and Senate)
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
allocation of future PPP funds for banks between $10 - $50 billion in assets,
SBA system crashes,
difficulty inputting loans,
large bank preferential access to the SBA for inputting their loans,
automated bots overwhelming SBA system,
slow processing times to input loans,
exhaustion of the under $10 billion in bank asset funding tranche,
loan forgiveness, and
payment of PPP fees to the originating bank
(House, Senate, FDIC, OCC, Federal Reserve, CFPB)
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
difference in taxing origination fee income from PPP loans between tax paying community banks and tax-exempt credit unions
(House)
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
requirement that 75% of loan proceeds must be spent on retaining payroll,
straight-forward approach to loan forgiveness,
loan forgiveness calculator,
presumption of borrower compliance for loans of $1 million and under, and
questions related to loan forgiveness
(House and Senate)
Letters -
Comment Letter to the Office of Comptroller of the Currency (OCC) regarding: Joint Notice of Proposed Rulemaking - Request for Comment on Community Reinvestment Act Regulations - Office of Comptroller of the Currency, Docker ID OCC-2018-0008 and RIN 1557-AE34; Federal Deposit Insurance Corporation, RIN 3064-AF22 (OCC and FDIC)
Letter to the Federal Deposit Insurance Corporation (FDIC), OCC and Federal Reserve regarding providing financial services to non-customers and the unbanked during the COVID-19 crisis (FDIC, OCC, Federal Reserve and House)
Letter to House and Senate regarding Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
the process for submitting closed loans to the SBA,
borrower forgiveness,
submitting SBAs form 1502,
amount of the loan to be forgiven,
forgiveness calculator,
percentage of proceeds used for payroll versus non-payroll expenses,
consequences of not spending 75% of loan proceeds on payroll,
what constitutes full-time staff and new hires,
are payments made in the 8 week period limited to cash payroll versus accrued and the impact on forgiveness,
form of proof or documentation to qualify for forgiveness,
payroll and forgivable expenses for the self-employed,
self-rental income qualifying for forgiveness,
intended way to remit forgiveness amounts to lenders,
difference in taxing origination fee income from PPP loans between tax paying community banks and tax-exempt credit unions, and
eligibility for employee retention credit (ERC)
(House and Senate)
Letter to House and Senate regarding Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
flexible spending of loan proceeds - 75%/25% split,
flexible options for the 8 week period to spend funds,
presumption of borrower compliance for loans under $1 million,
easy to apply approach to loan forgiveness,
loan forgiveness calculator,
streamline form for self-employed and independent contractors, and
preserve payroll and other business expense deductions for PPP loan recipients
(House and Senate)
Comment Letter to the NCUA regarding proposed rule about combination transactions with non-credit unions, credit union asset acquisitions - RIN 3313-AF10 (NCUA)
Comment letter to the FDIC regarding unsafe and unsound banking practices, brokered deposit restrictions - RIN 3064-AE94
Comment Letter to the Federal Housing Finance Agency (FHFA) regarding request for information about membership eligibility in Federal Home Loan Banks (FHFA)
Comment Letter to the FDIC regarding proposed rule about parent companies of industrial banks and industrial loan companies (ILCs), RIN 3064-AF31 (FDIC and House)
Action Alerts -
Action Alert regarding replenishing the SBAs small business loan fund (PPP) (Phase 2) (House and Senate)
Action Alert regarding fixing various problems with the SBAs PPP (House and Senate)
Action Alert regarding recommendations for improvement and answers to questions about the SBAs PPP loans (House and Senate)
Action Alert regarding easing proposed brokered deposit restrictions (FDIC)
Action Alert regarding passing necessary SBA PPP reforms (Senate and House)
Action Alert regarding NCUA proposal to increase transparency of credit unions acquiring community banks, allowing the largest credit unions to issue subordinated debt, holding hearings on credit unions weaponizing their tax-exempt status to purchase community banks (NCUA, House and Senate)
Miscellaneous -
Joint (OCC and FDIC) Notice of Proposed Rulemaking on Community Reinvestment Act [CRA] Regulations, the modernization of the CRA (House)
Closing the Industrial Loan Company (ILC) loophole (House)
On-line lender versus community bank lender performance during the COVID-10 crisis (House and Senate)
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Consumer Financial Protection Bureau (CFPB), Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), Treasury - Dept of, Small Business Administration (SBA), Federal Reserve System, Federal Housing Finance Agency (FHFA), Natl Credit Union Administration (NCUA)
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
David |
Schroeder |
|
|
19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code FIN
16. Specific lobbying issues
Legislation and Regulation -
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
interest rate below break-even,
short PPP loan terms,
restricted use of PPP loan proceeds, and
lender liability, and
a PPP related liquidity facility
(Treasury, SBA, House, Senate and Federal Reserve)
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
lender participation in the PPP,
general availability of SBA forms,
access to the SBAs portal,
obtaining log-in credentials,
SBA forms to obtain approval to become certified,
SBA website list of active SBA lenders,
SBA website list of PPP lenders,
SBA call center access,
late release of rules prior to the PPP going live,
confusion surrounding the guaranteed portion of the PPP loans,
bank board members not eligible to apply for PPP loans at their bank,
PPP related liquidity facility,
access to the SBA for answers to questions about the PPP,
conflicting messaging from the SBA, and
consistent need for additional guidance from the SBA and Treasury on various aspects of the PPP
(House and Senate)
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
SBA technology supporting the PPP including delays in accessing E-Tran and the Lender Gateway,
additional funding for (replenishing) the PPP,
allocation of 25% of future PPP funds for banks under $50 billion in assets, and
the creation of a Federal Reserve facility to support lending by providing term financing backed by PPP loans
(Treasury, SBA, Federal Reserve, House and Senate)
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
allocation of 25% of future PPP funds for banks under $50 billion in assets,
more workable loan terms - interest rates below funding costs,
more flexible timing for loan disbursements
expanding the program to meet non-payroll expenses,
lender safe harbor, and
suspending the beneficial ownership rule for non-current customers
(House and Senate)
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
allocation of future PPP funds for banks between $10 - $50 billion in assets,
SBA system crashes,
difficulty inputting loans,
large bank preferential access to the SBA for inputting their loans,
automated bots overwhelming SBA system,
slow processing times to input loans,
exhaustion of the under $10 billion in bank asset funding tranche,
loan forgiveness, and
payment of PPP fees to the originating bank
(House, Senate, FDIC, OCC, Federal Reserve, CFPB)
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
difference in taxing origination fee income from PPP loans between tax paying community banks and tax-exempt credit unions
(House)
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
requirement that 75% of loan proceeds must be spent on retaining payroll,
straight-forward approach to loan forgiveness,
loan forgiveness calculator,
presumption of borrower compliance for loans of $1 million and under, and
questions related to loan forgiveness
(House and Senate)
Letters -
Comment Letter to the Office of Comptroller of the Currency (OCC) regarding: Joint Notice of Proposed Rulemaking - Request for Comment on Community Reinvestment Act Regulations - Office of Comptroller of the Currency, Docker ID OCC-2018-0008 and RIN 1557-AE34; Federal Deposit Insurance Corporation, RIN 3064-AF22 (OCC and FDIC)
Letter to the Federal Deposit Insurance Corporation (FDIC), OCC and Federal Reserve regarding providing financial services to non-customers and the unbanked during the COVID-19 crisis (FDIC, OCC, Federal Reserve and House)
Letter to House and Senate regarding Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
the process for submitting closed loans to the SBA,
borrower forgiveness,
submitting SBAs form 1502,
amount of the loan to be forgiven,
forgiveness calculator,
percentage of proceeds used for payroll versus non-payroll expenses,
consequences of not spending 75% of loan proceeds on payroll,
what constitutes full-time staff and new hires,
are payments made in the 8 week period limited to cash payroll versus accrued and the impact on forgiveness,
form of proof or documentation to qualify for forgiveness,
payroll and forgivable expenses for the self-employed,
self-rental income qualifying for forgiveness,
intended way to remit forgiveness amounts to lenders,
difference in taxing origination fee income from PPP loans between tax paying community banks and tax-exempt credit unions, and
eligibility for employee retention credit (ERC)
(House and Senate)
Letter to House and Senate regarding Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
flexible spending of loan proceeds - 75%/25% split,
flexible options for the 8 week period to spend funds,
presumption of borrower compliance for loans under $1 million,
easy to apply approach to loan forgiveness,
loan forgiveness calculator,
streamline form for self-employed and independent contractors, and
preserve payroll and other business expense deductions for PPP loan recipients
(House and Senate)
Comment Letter to the NCUA regarding proposed rule about combination transactions with non-credit unions, credit union asset acquisitions - RIN 3313-AF10 (NCUA)
Comment letter to the FDIC regarding unsafe and unsound banking practices, brokered deposit restrictions - RIN 3064-AE94
Comment Letter to the Federal Housing Finance Agency (FHFA) regarding request for information about membership eligibility in Federal Home Loan Banks (FHFA)
Comment Letter to the FDIC regarding proposed rule about parent companies of industrial banks and industrial loan companies (ILCs), RIN 3064-AF31 (FDIC and House)
Action Alerts -
Action Alert regarding replenishing the SBAs small business loan fund (PPP) (Phase 2) (House and Senate)
Action Alert regarding fixing various problems with the SBAs PPP (House and Senate)
Action Alert regarding recommendations for improvement and answers to questions about the SBAs PPP loans (House and Senate)
Action Alert regarding easing proposed brokered deposit restrictions (FDIC)
Action Alert regarding passing necessary SBA PPP reforms (Senate and House)
Action Alert regarding NCUA proposal to increase transparency of credit unions acquiring community banks, allowing the largest credit unions to issue subordinated debt, holding hearings on credit unions weaponizing their tax-exempt status to purchase community banks (NCUA, House and Senate)
Miscellaneous -
Joint (OCC and FDIC) Notice of Proposed Rulemaking on Community Reinvestment Act [CRA] Regulations, the modernization of the CRA (House)
Closing the Industrial Loan Company (ILC) loophole (House)
On-line lender versus community bank lender performance during the COVID-10 crisis (House and Senate)
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Consumer Financial Protection Bureau (CFPB), Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), Treasury - Dept of, Small Business Administration (SBA), Federal Reserve System, Federal Housing Finance Agency (FHFA), Natl Credit Union Administration (NCUA)
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
David |
Schroeder |
|
|
19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code AGR
16. Specific lobbying issues
Legislation and Regulation -
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
interest rate below break-even,
short PPP loan terms,
restricted use of PPP loan proceeds, and
lender liability, and
a PPP related liquidity facility
(Treasury, SBA, House, Senate and Federal Reserve)
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
lender participation in the PPP,
general availability of SBA forms,
access to the SBAs portal,
obtaining log-in credentials,
SBA forms to obtain approval to become certified,
SBA website list of active SBA lenders,
SBA website list of PPP lenders,
SBA call center access,
late release of rules prior to the PPP going live,
confusion surrounding the guaranteed portion of the PPP loans,
bank board members not eligible to apply for PPP loans at their bank,
PPP related liquidity facility,
access to the SBA for answers to questions about the PPP,
conflicting messaging from the SBA, and
consistent need for additional guidance from the SBA and Treasury on various aspects of the PPP
(House and Senate)
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
SBA technology supporting the PPP including delays in accessing E-Tran and the Lender Gateway,
additional funding for (replenishing) the PPP,
allocation of 25% of future PPP funds for banks under $50 billion in assets, and
the creation of a Federal Reserve facility to support lending by providing term financing backed by PPP loans
(Treasury, SBA, Federal Reserve, House and Senate)
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
allocation of 25% of future PPP funds for banks under $50 billion in assets,
more workable loan terms - interest rates below funding costs,
more flexible timing for loan disbursements
expanding the program to meet non-payroll expenses,
lender safe harbor, and
suspending the beneficial ownership rule for non-current customers
(House and Senate)
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
allocation of future PPP funds for banks between $10 - $50 billion in assets,
SBA system crashes,
difficulty inputting loans,
large bank preferential access to the SBA for inputting their loans,
automated bots overwhelming SBA system,
slow processing times to input loans,
exhaustion of the under $10 billion in bank asset funding tranche,
loan forgiveness, and
payment of PPP fees to the originating bank
(House, Senate, FDIC, OCC, Federal Reserve, CFPB)
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
difference in taxing origination fee income from PPP loans between tax paying community banks and tax-exempt credit unions
(House)
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
requirement that 75% of loan proceeds must be spent on retaining payroll,
straight-forward approach to loan forgiveness,
loan forgiveness calculator,
presumption of borrower compliance for loans of $1 million and under, and
questions related to loan forgiveness
(House and Senate)
Letters -
Comment Letter to the Office of Comptroller of the Currency (OCC) regarding: Joint Notice of Proposed Rulemaking - Request for Comment on Community Reinvestment Act Regulations - Office of Comptroller of the Currency, Docker ID OCC-2018-0008 and RIN 1557-AE34; Federal Deposit Insurance Corporation, RIN 3064-AF22 (OCC and FDIC)
Letter to the Federal Deposit Insurance Corporation (FDIC), OCC and Federal Reserve regarding providing financial services to non-customers and the unbanked during the COVID-19 crisis (FDIC, OCC, Federal Reserve and House)
Letter to House and Senate regarding Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
the process for submitting closed loans to the SBA,
borrower forgiveness,
submitting SBAs form 1502,
amount of the loan to be forgiven,
forgiveness calculator,
percentage of proceeds used for payroll versus non-payroll expenses,
consequences of not spending 75% of loan proceeds on payroll,
what constitutes full-time staff and new hires,
are payments made in the 8 week period limited to cash payroll versus accrued and the impact on forgiveness,
form of proof or documentation to qualify for forgiveness,
payroll and forgivable expenses for the self-employed,
self-rental income qualifying for forgiveness,
intended way to remit forgiveness amounts to lenders,
difference in taxing origination fee income from PPP loans between tax paying community banks and tax-exempt credit unions, and
eligibility for employee retention credit (ERC)
(House and Senate)
Letter to House and Senate regarding Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
flexible spending of loan proceeds - 75%/25% split,
flexible options for the 8 week period to spend funds,
presumption of borrower compliance for loans under $1 million,
easy to apply approach to loan forgiveness,
loan forgiveness calculator,
streamline form for self-employed and independent contractors, and
preserve payroll and other business expense deductions for PPP loan recipients
(House and Senate)
Comment Letter to the NCUA regarding proposed rule about combination transactions with non-credit unions, credit union asset acquisitions - RIN 3313-AF10 (NCUA)
Action Alerts -
Action Alert regarding replenishing the SBAs small business loan fund (PPP) (Phase 2) (House and Senate)
Action Alert regarding fixing various problems with the SBAs PPP (House and Senate)
Action Alert regarding recommendations for improvement and answers to questions about the SBAs PPP loans (House and Senate)
Action Alert regarding passing necessary SBA PPP reforms (Senate and House)
Action Alert regarding NCUA proposal to increase transparency of credit unions acquiring community banks, allowing the largest credit unions to issue subordinated debt, holding hearings on credit unions weaponizing their tax-exempt status to purchase community banks (NCUA, House and Senate)
Miscellaneous -
Joint (OCC and FDIC) Notice of Proposed Rulemaking on Community Reinvestment Act [CRA] Regulations, the modernization of the CRA (House)
On-line lender versus community bank lender performance during the COVID-10 crisis (House and Senate)
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Consumer Financial Protection Bureau (CFPB), Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), Treasury - Dept of, Small Business Administration (SBA), Federal Reserve System, Natl Credit Union Administration (NCUA)
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
David |
Schroeder |
|
|
19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code CSP
16. Specific lobbying issues
Letters -
Comment Letter to the Office of Comptroller of the Currency (OCC) regarding: Joint Notice of Proposed Rulemaking - Request for Comment on Community Reinvestment Act Regulations - Office of Comptroller of the Currency, Docker ID OCC-2018-0008 and RIN 1557-AE34; Federal Deposit Insurance Corporation, RIN 3064-AF22 (OCC and FDIC)
Letter to the Federal Deposit Insurance Corporation (FDIC), OCC and Federal Reserve regarding providing financial services to non-customers and the unbanked during the COVID-19 crisis (FDIC, OCC, Federal Reserve and House)
Comment Letter to the NCUA regarding proposed rule about combination transactions with non-credit unions, credit union asset acquisitions - RIN 3313-AF10 (NCUA)
Action Alerts -
Action Alert regarding NCUA proposal to increase transparency of credit unions acquiring community banks, allowing the largest credit unions to issue subordinated debt, holding hearings on credit unions weaponizing their tax-exempt status to purchase community banks (NCUA, House and Senate)
Miscellaneous -
Joint (OCC and FDIC) Notice of Proposed Rulemaking on Community Reinvestment Act [CRA] Regulations, the modernization of the CRA (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), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Natl Credit Union Administration (NCUA)
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
David |
Schroeder |
|
|
19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code SMB
16. Specific lobbying issues
Legislation and Regulation -
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
interest rate below break-even,
short PPP loan terms,
restricted use of PPP loan proceeds, and
lender liability, and
a PPP related liquidity facility
(Treasury, SBA, House, Senate and Federal Reserve)
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
lender participation in the PPP,
general availability of SBA forms,
access to the SBAs portal,
obtaining log-in credentials,
SBA forms to obtain approval to become certified,
SBA website list of active SBA lenders,
SBA website list of PPP lenders,
SBA call center access,
late release of rules prior to the PPP going live,
confusion surrounding the guaranteed portion of the PPP loans,
bank board members not eligible to apply for PPP loans at their bank,
PPP related liquidity facility,
access to the SBA for answers to questions about the PPP,
conflicting messaging from the SBA, and
consistent need for additional guidance from the SBA and Treasury on various aspects of the PPP
(House and Senate)
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
SBA technology supporting the PPP including delays in accessing E-Tran and the Lender Gateway,
additional funding for (replenishing) the PPP,
allocation of 25% of future PPP funds for banks under $50 billion in assets, and
the creation of a Federal Reserve facility to support lending by providing term financing backed by PPP loans
(Treasury, SBA, Federal Reserve, House and Senate)
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
allocation of 25% of future PPP funds for banks under $50 billion in assets,
more workable loan terms - interest rates below funding costs,
more flexible timing for loan disbursements
expanding the program to meet non-payroll expenses,
lender safe harbor, and
suspending the beneficial ownership rule for non-current customers
(House and Senate)
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
allocation of future PPP funds for banks between $10 - $50 billion in assets,
SBA system crashes,
difficulty inputting loans,
large bank preferential access to the SBA for inputting their loans,
automated bots overwhelming SBA system,
slow processing times to input loans,
exhaustion of the under $10 billion in bank asset funding tranche,
loan forgiveness, and
payment of PPP fees to the originating bank
(House, Senate, FDIC, OCC, Federal Reserve, CFPB)
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
difference in taxing origination fee income from PPP loans between tax paying community banks and tax-exempt credit unions
(House)
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
requirement that 75% of loan proceeds must be spent on retaining payroll,
straight-forward approach to loan forgiveness,
loan forgiveness calculator,
presumption of borrower compliance for loans of $1 million and under, and
questions related to loan forgiveness
(House and Senate)
Letters -
Comment Letter to the Office of Comptroller of the Currency (OCC) regarding: Joint Notice of Proposed Rulemaking - Request for Comment on Community Reinvestment Act Regulations - Office of Comptroller of the Currency, Docker ID OCC-2018-0008 and RIN 1557-AE34; Federal Deposit Insurance Corporation, RIN 3064-AF22 (OCC and FDIC)
Letter to the Federal Deposit Insurance Corporation (FDIC), OCC and Federal Reserve regarding providing financial services to non-customers and the unbanked during the COVID-19 crisis (FDIC, OCC, Federal Reserve and House)
Letter to House and Senate regarding Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
the process for submitting closed loans to the SBA,
borrower forgiveness,
submitting SBAs form 1502,
amount of the loan to be forgiven,
forgiveness calculator,
percentage of proceeds used for payroll versus non-payroll expenses,
consequences of not spending 75% of loan proceeds on payroll,
what constitutes full-time staff and new hires,
are payments made in the 8 week period limited to cash payroll versus accrued and the impact on forgiveness,
form of proof or documentation to qualify for forgiveness,
payroll and forgivable expenses for the self-employed,
self-rental income qualifying for forgiveness,
intended way to remit forgiveness amounts to lenders,
difference in taxing origination fee income from PPP loans between tax paying community banks and tax-exempt credit unions, and
eligibility for employee retention credit (ERC)
(House and Senate)
Letter to House and Senate regarding Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
flexible spending of loan proceeds - 75%/25% split,
flexible options for the 8 week period to spend funds,
presumption of borrower compliance for loans under $1 million,
easy to apply approach to loan forgiveness,
loan forgiveness calculator,
streamline form for self-employed and independent contractors, and
preserve payroll and other business expense deductions for PPP loan recipients
(House and Senate)
Comment Letter to the NCUA regarding proposed rule about combination transactions with non-credit unions, credit union asset acquisitions - RIN 3313-AF10 (NCUA)
Action Alerts -
Action Alert regarding replenishing the SBAs small business loan fund (PPP) (Phase 2) (House and Senate)
Action Alert regarding fixing various problems with the SBAs PPP (House and Senate)
Action Alert regarding recommendations for improvement and answers to questions about the SBAs PPP loans (House and Senate)
Action Alert regarding passing necessary SBA PPP reforms (Senate and House)
Action Alert regarding NCUA proposal to increase transparency of credit unions acquiring community banks, allowing the largest credit unions to issue subordinated debt, holding hearings on credit unions weaponizing their tax-exempt status to purchase community banks (NCUA, House and Senate)
Miscellaneous -
Joint (OCC and FDIC) Notice of Proposed Rulemaking on Community Reinvestment Act [CRA] Regulations, the modernization of the CRA (House)
On-line lender versus community bank lender performance during the COVID-10 crisis (House and Senate)
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Consumer Financial Protection Bureau (CFPB), Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), Treasury - Dept of, Small Business Administration (SBA), Federal Reserve System, Natl Credit Union Administration (NCUA)
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
David |
Schroeder |
|
|
19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code TAX
16. Specific lobbying issues
Legislation and Regulation -
Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
difference in taxing origination fee income from PPP loans between tax paying community banks and tax-exempt credit unions
(House)
Letters -
Comment Letter to the Office of Comptroller of the Currency (OCC) regarding: Joint Notice of Proposed Rulemaking - Request for Comment on Community Reinvestment Act Regulations - Office of Comptroller of the Currency, Docker ID OCC-2018-0008 and RIN 1557-AE34; Federal Deposit Insurance Corporation, RIN 3064-AF22 (OCC and FDIC)
Letter to House and Senate regarding Coronavirus Aid, Relief, and Economic Security (CARES) Acts Paycheck Protection Program (PPP), and the Treasury and SBA implementation -
the process for submitting closed loans to the SBA,
borrower forgiveness,
submitting SBAs form 1502,
amount of the loan to be forgiven,
forgiveness calculator,
percentage of proceeds used for payroll versus non-payroll expenses,
consequences of not spending 75% of loan proceeds on payroll,
what constitutes full-time staff and new hires,
are payments made in the 8 week period limited to cash payroll versus accrued and the impact on forgiveness,
form of proof or documentation to qualify for forgiveness,
payroll and forgivable expenses for the self-employed,
self-rental income qualifying for forgiveness,
intended way to remit forgiveness amounts to lenders,
difference in taxing origination fee income from PPP loans between tax paying community banks and tax-exempt credit unions, and
eligibility for employee retention credit (ERC)
(House and Senate)
Comment Letter to the NCUA regarding proposed rule about combination transactions with non-credit unions, credit union asset acquisitions - RIN 3313-AF10 (NCUA)
Action Alerts -
Action Alert regarding NCUA proposal to increase transparency of credit unions acquiring community banks, allowing the largest credit unions to issue subordinated debt, holding hearings on credit unions weaponizing their tax-exempt status to purchase community banks (NCUA, House and Senate)
Miscellaneous -
Joint (OCC and FDIC) Notice of Proposed Rulemaking on Community Reinvestment Act [CRA] Regulations, the modernization of the CRA (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), Federal Deposit Insurance Corporation (FDIC), Natl Credit Union Administration (NCUA)
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
David |
Schroeder |
|
|
19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code ECN
16. Specific lobbying issues
Letters -
Comment Letter to the Office of Comptroller of the Currency (OCC) regarding: Joint Notice of Proposed Rulemaking - Request for Comment on Community Reinvestment Act Regulations - Office of Comptroller of the Currency, Docker ID OCC-2018-0008 and RIN 1557-AE34; Federal Deposit Insurance Corporation, RIN 3064-AF22 (OCC and FDIC)
Comment Letter to the NCUA regarding proposed rule about combination transactions with non-credit unions, credit union asset acquisitions - RIN 3313-AF10 (NCUA)
Action Alerts -
Action Alert regarding NCUA proposal to increase transparency of credit unions acquiring community banks, allowing the largest credit unions to issue subordinated debt, holding hearings on credit unions weaponizing their tax-exempt status to purchase community banks (NCUA, House and Senate)
Miscellaneous -
Joint (OCC and FDIC) Notice of Proposed Rulemaking on Community Reinvestment Act [CRA] Regulations, the modernization of the CRA (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), Federal Deposit Insurance Corporation (FDIC), Natl Credit Union Administration (NCUA)
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
David |
Schroeder |
|
|
19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
Information Update Page - Complete ONLY where registration information has changed.
20. Client new address
| Address |
|
||||||
| City |
|
State |
|
Zip Code |
|
Country |
|
21. Client new principal place of business (if different than line 20)
| City |
|
State |
|
Zip Code |
|
Country |
|
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
|
|
||||||||
| 1 |
|
3 |
|
||||||
| 2 |
|
4 |
|
ISSUE UPDATE
24. General lobbying issue that no longer pertains
|
|
|
|
|
|
|
|
|
AFFILIATED ORGANIZATIONS
25. Add the following affiliated organization(s)
Internet Address:
| Name | Address |
Principal Place of Business (city and state or country) |
||||||||||||
| ||||||||||||||
|
||||||||||||||
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 | ||||||||||
| ||||||||||||||
|
% | |||||||||||||
28. Name of each previously reported foreign entity that no longer owns, or controls, or is affiliated with the registrant, client or affiliated organization
| 1 | 3 | 5 |
| 2 | 4 | 6 |
CONVICTIONS DISCLOSURE
29. Have any of the lobbyists listed on this report been convicted in a Federal or State Court of an offense involving bribery,
extortion, embezzlement, an illegal kickback, tax evasion, fraud, a conflict of interest, making a false statement, perjury, or money laundering?
| Lobbyist Name | Description of Offense(s) |