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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 | |
City | Springfield |
State | IL |
Zip Code | 62703 |
Country | USA |
3. Principal place of business (if different than line 2)
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Zip Code | |
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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 | 2012 |
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 | |||||||||
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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. | ||||||||
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 Vice President Federal Governmental Relations |
Date | 04/16/2012 |
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
Rein in Significantly Important Financial institution (SIFI) with focused regulation including higher capital and liquidity requirements
Shield community banks from the Dodd-Frank required increase in the deposit insurance fund reserve ratio from 1.15% to 1.35%
Consumer Financial Protection focus on too-big-to-fail banks and financial firms and shadow financial industry, high standards for
consumer compliance required of community banks, accommodation of community banks in serving the needs of their customers,
broad definition of covered person, consolidation of RESPA and TILA forms, regulatory compliance and increased regulatory burden, and regulatory relief
Ensure the small debit card issuer exemption in the Dodd-Frank (Durbin Amendment) is working to protect community banks
Downsizing too-big-to-fail banks over a five-years and the regulation of too-big-to-fail banks and financial firms and the shadow financial industry, separation of banking and commerce, expansion of the Volker Rule and restoration of Glass-Steagall Act
Overzealous bank regulatory examinations regulator, senior management, and examiner attitudes and practices, treatment of Commercial Real Estate, excessive write-downs, arbitrary capital requirements, public enforcement actions, reform the appellate process, and community bank closures
Tiered regulation and supervision for community banks
Accounting changes FASB proposed fair value disclosures requiring parenthetical disclosures for all financial instruments carried at amortized cost, PCBOA proposal to expand the scope of the independent accountant during the audit and mandatory auditor rotation, amortizing commercial real estate losses over 10 years for regulatory capital purposes
Secondary mortgage lending reforms curb imprudent lending practices without impacting responsible lenders and loan products designed to meet the diverse needs of community bank customers and their communities
Reform of the housing GSEs - community bank access to a strong, impartial secondary market for residential loans that is financially strong and reliable, privately capitalized cooperative entities with limited mission
Expansion of the Farm Credit System, Rural Community Investments proposal, focus on wholesale funding for community banks and providing correspondent services rather than direct retail competition with community banks
Equitable capital rules which do not disadvantage community banks, higher capital and liquidity requirements for SIFIs, inclusion of accumulated and other comprehensive income in calculation of Tier 1 regulatory capital, and elimination of the 1.25% Allowance for Loan and Lease losses disallowance for regulatory capital purposes)
Overdraft programs uncoordinated regulatory response, address proposed risks with specific banks in the context of the regulatory examination, defer to CFPB
Maintain the Federal Home Loan Bank System and preserve their special functions and purposes
Permanent closing of the ILC loophole
Fairly compensate Fannie and Freddie preferred shareholders by restoring the share value and dividends
H.R. 1697 (and S. 1600) - Communities First Act (Community bank regulatory and tax relief) (all sections)
H.R. 1418 (and S. 509 renumbered in the Senate to S. 2231) - Small Business Lending Enhancement Act of 2011 (Expansion of credit unions member business lending powers) (all sections)
H.R. 3993 Capital Access for Small Business and Jobs Act (Credit union access to outside capital) (all sections)
H.R. 3461 (and 2160) Financial institutions Examination Fairness Act (To improve the examination of depository institutions) (all sections)
H.R. 1365 Capital Access for Main Street Act of 2011 (loan loss amortization) (all sections)
Five-year extension of the Transaction Account Guarantee (TAG) program
Presidents FY2013 budget request - $61billion fee the largest banks will be assessed to pay for their role in the financial crisis
Comment Letter to the U.S. Department of Agriculture regarding the USDAs Rural Business-Cooperative Services interim final rule on Rural Business Investment Companies RIN: 0570-AA80
Comment Letter to the Federal Housing Finance Agency (RIN 2590-AA38) regarding the Agencys proposed rule to amend the community support regulation to require the Federal Home Loan Banks, as opposed to the FHFA, to monitor and assess the eligibility of each FHLBank member for access to long-term advances through compliance with the Community Reinvestment Act of 1977 and first-time homebuyer standards
Comment letter to the Board of Governors of the Federal Reserve System (Docket No. 2011-1432 and RIN 7100-AD82), Federal Deposit Insurance Corporation, Treasury/Office of Comptroller of the Currency, and the Securities and Exchange Commission regarding the implementation of Section 619 of the Dodd-Frank Wall Street Reform Act which contains certain prohibitions and restrictions on the ability of a banking entity and nonbank finance companies supervised by the board to engage in propriety trading and have certain interests in, and relationships with, hedge funds and private equity funds
Comment letter to the Treasury/Consumer Financial Protection Bureau (Docket No. CFPB-2012-0010 and RIN: 3170-AA20) proposed rule regarding the confidential treatment of privileged information obtained from persons in connection with its exercise of authority under Federal consumer financial law
Increasing conforming loan limits in the sub-areas of the Chicago metropolitan statistical area (MSA) or in the MSA as a whole
H.R. 3606 Jumpstart Our Business Startups Act (SEC thresholds for registration and deregistration (H.R. 2167 (H.R. 1965) and H.R. 4088) (also H.R. 1070, H.R. 2930 and H.R. 2940)
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Agriculture - Dept of (USDA), Federal Deposit Insurance Commission (FDIC), Federal Reserve System, Federal Housing Finance Board (FHFB), Treasury - Dept of, Securities & Exchange Commission (SEC)
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
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
Rein in Significantly Important Financial institution (SIFI) with focused regulation including higher capital and liquidity requirements
Shield community banks from the Dodd-Frank required increase in the deposit insurance fund reserve ratio from 1.15% to 1.35%
Consumer Financial Protection focus on too-big-to-fail banks and financial firms and shadow financial industry, high standards for
consumer compliance required of community banks, accommodation of community banks in serving the needs of their customers,
broad definition of covered person, consolidation of RESPA and TILA forms, regulatory compliance and increased regulatory burden, and regulatory relief
Ensure the small debit card issuer exemption in the Dodd-Frank (Durbin Amendment) is working to protect community banks
Downsizing too-big-to-fail banks over a five-years and the regulation of too-big-to-fail banks and financial firms and the shadow financial industry, separation of banking and commerce, expansion of the Volker Rule and restoration of Glass-Steagall Act
Overzealous bank regulatory examinations regulator, senior management, and examiner attitudes and practices, treatment of Commercial Real Estate, excessive write-downs, arbitrary capital requirements, public enforcement actions, reform the appellate process, and community bank closures
Tiered regulation and supervision for community banks
Accounting changes FASB proposed fair value disclosures requiring parenthetical disclosures for all financial instruments carried at amortized cost, PCBOA proposal to expand the scope of the independent accountant during the audit and mandatory auditor rotation, amortizing commercial real estate losses over 10 years for regulatory capital purposes
Secondary mortgage lending reforms curb imprudent lending practices without impacting responsible lenders and loan products designed to meet the diverse needs of community bank customers and their communities
Reform of the housing GSEs - community bank access to a strong, impartial secondary market for residential loans that is financially strong and reliable, privately capitalized cooperative entities with limited mission
Expansion of the Farm Credit System, Rural Community Investments proposal, focus on wholesale funding for community banks and providing correspondent services rather than direct retail competition with community banks
Equitable capital rules which do not disadvantage community banks, higher capital and liquidity requirements for SIFIs, inclusion of accumulated and other comprehensive income in calculation of Tier 1 regulatory capital, and elimination of the 1.25% Allowance for Loan and Lease losses disallowance for regulatory capital purposes)
Overdraft programs uncoordinated regulatory response, address proposed risks with specific banks in the context of the regulatory examination, defer to CFPB
Maintain the Federal Home Loan Bank System and preserve their special functions and purposes
Permanent closing of the ILC loophole
Fairly compensate Fannie and Freddie preferred shareholders by restoring the share value and dividends
H.R. 1697 (and S. 1600) - Communities First Act (Community bank regulatory and tax relief) (all sections)
H.R. 1418 (and S. 509 renumbered in the Senate to S. 2231) - Small Business Lending Enhancement Act of 2011 (Expansion of credit unions member business lending powers) (all sections)
H.R. 3993 Capital Access for Small Business and Jobs Act (Credit union access to outside capital) (all sections)
H.R. 3461 (and 2160) Financial institutions Examination Fairness Act (To improve the examination of depository institutions) (all sections)
H.R. 1365 Capital Access for Main Street Act of 2011 (loan loss amortization) (all sections)
Five-year extension of the Transaction Account Guarantee (TAG) program
Presidents FY2013 budget request - $61billion fee the largest banks will be assessed to pay for their role in the financial crisis
Comment Letter to the U.S. Department of Agriculture regarding the USDAs Rural Business-Cooperative Services interim final rule on Rural Business Investment Companies RIN: 0570-AA80
Comment Letter to the Federal Housing Finance Agency (RIN 2590-AA38) regarding the Agencys proposed rule to amend the community support regulation to require the Federal Home Loan Banks, as opposed to the FHFA, to monitor and assess the eligibility of each FHLBank member for access to long-term advances through compliance with the Community Reinvestment Act of 1977 and first-time homebuyer standards
Comment letter to the Board of Governors of the Federal Reserve System (Docket No. 2011-1432 and RIN 7100-AD82), Federal Deposit Insurance Corporation, Treasury/Office of Comptroller of the Currency, and the Securities and Exchange Commission regarding the implementation of Section 619 of the Dodd-Frank Wall Street Reform Act which contains certain prohibitions and restrictions on the ability of a banking entity and nonbank finance companies supervised by the board to engage in propriety trading and have certain interests in, and relationships with, hedge funds and private equity funds
Comment letter to the Treasury/Consumer Financial Protection Bureau (Docket No. CFPB-2012-0010 and RIN: 3170-AA20) proposed rule regarding the confidential treatment of privileged information obtained from persons in connection with its exercise of authority under Federal consumer financial law
Increasing conforming loan limits in the sub-areas of the Chicago metropolitan statistical area (MSA) or in the MSA as a whole
H.R. 3606 Jumpstart Our Business Startups Act (SEC thresholds for registration and deregistration (H.R. 2167 (H.R. 1965) and H.R. 4088) (also H.R. 1070, H.R. 2930 and H.R. 2940)
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Agriculture - Dept of (USDA), Federal Deposit Insurance Commission (FDIC), Federal Reserve System, Federal Housing Finance Board (FHFB), Securities & Exchange Commission (SEC), 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 |
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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
Expansion of the Farm Credit System, "Rural Community Investments" proposal, focus on wholesale funding for community banks and providing correspondent services rather than direct retail competition with community banks
Comment Letter to the U.S. Department of Agriculture regarding the USDA's Rural Business-Cooperative Service's interim final rule on Rural Business Investment Companies RIN 0570-AA80
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Agriculture - Dept of (USDA)
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
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
Secondary mortgage lending reforms curb imprudent lending practices without impacting responsible lenders and loan products designed to meet the diverse needs of community bank customers and their communities
Increasing conforming loan limits in the sub-areas of the Chicago metropolitan statistical area (MSA) or in the MSA as a whole
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
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
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
Comment Letter to the U.S. Department of Agriculture regarding the USDA's Rural Business-Cooperative Service's interim final rule on Rural Business Investment Companies RIN: 0570-AA80
H.R. 1418 (and S. 509 - renumbered in the Senate to S. 2231) - Small Business Lending Enhancement Act of 2011 (Expansion of credit unions' member business lending powers (all sections)
H.R. 3606 Jumpstart Our Business Startups Act (SEC thresholds for registration and deregistration (H.R. 2167 (H.R. 1965) and H.R. 4088) (also H.R. 1070, H.R. 2930 and H.R. 2940)
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Agriculture - Dept of (USDA)
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
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
H.R. 1418 (and S. 509 renumbered in the Senate to S. 2231) - Small Business Lending Enhancement Act of 2011 (Expansion of credit unions member business lending powers) (all sections)
H.R. 3993 Capital Access for Small Business and Jobs Act (Credit union access to outside capital) (all sections)
Comment Letter to the U.S. Department of Agriculture regarding the USDAs Rural Business-Cooperative Services interim final rule on Rural Business Investment Companies RIN: 0570-AA80
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Agriculture - Dept of (USDA), Federal Deposit Insurance Commission (FDIC), 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 |
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|
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
H.R. 3606 - Jumpstart Our Business Startups Act (SEC thresholds for registration and deregistration (H.R. 2167 (H.R. 1965) and H.R. 4088) (also H.R. 1070, H.R. 2930 and H.R. 2940)
Comment Letter to the U.S. Department of Agriculture regarding the USDA's Rural Business-Cooperative Service's interim final rule on Rural Business Investment Companies RIN: 0570-AA80
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Agriculture - Dept of (USDA)
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 |