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

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

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

15. General issue area code BAN

16. Specific lobbying issues

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate)

Too-to-Fail -
Reform the financial system. The severity of a future financial crisis. The perception and reality of too-big-to-fail. Taxpayer bailouts of mega banks and financial firms.

Mega bank size, complexity and interconnectedness, and candidacy for future bailouts. The number of community banks falling by more than half (currently 6,200 institutions) and now represent less than one-fifth of banking professions assets.

Causes of the mortgage meltdown and financial crisis. Protection of the nation and the banking profession from a repeat of massive financial destruction. Taxpayer-funded bailouts of too-big-to-fail banks and financial firms and their numerous violations of the law, often criminal violations.

Effectively management, supervision, discipline, or resolution of too-big-to-fail banks and financial firms. Mega bank multi-trillion dollars financial assistance. Community banks assistance and more than 500 failed community banks. Downsizing too-big-to-fail banks and financial firms.

The fundamental American constitutional right of equal justice under the law applicability when it comes to the mega banks. The U.S. two-tiered system of justice - too-big-to-fail banks and financial firms and everyone else. The Department of Justice (DOJ) - laggard in prosecuting crimes stemming from the financial crisis.

Banking regulators and the DOJ aggressively pursuing actions against community banks, their directors, and officers with board resolutions, MOUs, C&Ds, consent orders, monetary penalties, barring individuals from banking, criminal prosecution, and other actions. No mandatory Prompt Corrective Action (PCA) capital enforcement orders against any bank larger than $30 billion in assets, yet 1,400 PCAs against community banks. Evidence of a clear double standard.

Opponents of downsizing the mega banks (include their paid association cheerleaders) consistently blocking meaningful reforms and obfuscating the issue of too-big-to-fail for the benefit of large members and the detriment of everyone else.

Too-big-to-fail banks, directors, officers, or employees being - too-big-to-manage, too-big-to-regulate, too-big-to-fail, too-big-to-prosecute, too-big-to-jail, too-big-to-change, and clearly too-big-to-behave --- downsize.

Tiered Regulation and Supervision for Community Banks -
The Independent Community Bankers of Americas Plan for Prosperity-

Outsized risks taken by Wall Street mega banks during the financial crisis. The different modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a one-size-fits-all approach. Disproportionate burden of banking laws and regulations on community banks. Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks. Un-level playing field and a significant competitive disadvantage for community banks.

Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies.

Excessive, redundant and costly regulations. Regulatory accountability. Community banks dedicating resources to promoting economic growth. Steady increase in regulations over many decades. Regulatory threats to community banks and their communities.

The Plan for Prosperity regarding:
Basel III original intent.
additional capital for small holding companies - modernize the Federal Reserves Policy Statement.
Securities and Exchange Commission rules.
reforming mortgage lending.
accountability in bank exams by providing an appeals process.
bank oversight and examinations - targeting risks.
annual requirement for redundant privacy notices.
consumer regulation - inclusive and accountable CFPB governance.
arbitrary disparate impact fair lending causes of action.
viability of mutual banks with new charter options.
cost-benefit analysis to justify new rules.
red tape in small business lending - burdensome data collection.
community bank mortgage servicing.
Treasury Assistant Secretary for Community Banks.
subchapter S constraints.
five-year loss carryback - support for lending during economic downturns.
risk targeting in the Volcker Rule.

Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks.

Credit Union Taxation and Expansion of Powers -
Credit unions now indistinguishable from community banks, grown to control a significant share of the banking services market. Original business model now outdated. Credit unions strayed from founding purpose of serving individuals of modest means and with a common bond. Same financial services as community banks. Federal tax-exempt status, in exchange for serving their original mission is no longer justified. Credit unions should pay their fair share of income taxes.

Credit unions not adhering to a common bond or operating within a well-defined local community, neighborhood or rural district.

Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L). The exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks].

The Office of Management and Budget tax expenditure analysis - tax-exemption for credit unions result in loss of tax revenues of $9.46 billion over fiscal years 2014-2018.

Credit union expansion of commercial lending powers - increasing the percentage of assets cap on member business lending (MBL). Loan growth at the expense of tax-paying community banks. Fundamental altering the exclusive member-focused character of credit unions - a condition for their original tax exemption.

Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts. The same Call Report filing requirements for credit unions as those imposed on community banks.

Tax subsidy and level the playing field between credit unions and tax-paying community banks.

Farm Credit System -
Expansionist agenda of the Farm Credit System (FCS). FCS almost the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status. Tax advantages - unfair competitive advantage. Follow narrow historic mission - abolish or be subject to taxation and oversight and regulation.

Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives.

Support and cooperation of Farm Credit Administration (FCA) - FCS straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities. FCS significant systemic and taxpayer bail-out risks.

The FCS (only GSE) in active competition with community banks. Public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks).

Funding and tax benefits impact on community banks. FCS not following its narrow historical mission. Follow narrow mission or abolish System. Abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity.

FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight.

Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks.

Enhanced Cyber, Data and Payment Card Security -
Establish a federal data security standard and notice requirement for all entities that store consumer data comparable to the Gramm-Leach-Bliley Act (GLBA) standards that apply to community banks. Shifting the liability for all costs associated with the data breach - including fraud losses and the cost of card reissuance - to the party that caused the breach.

Consumer Financial Protection Bureau Mortgage Lending and Housing Finance Reform -
Imprudent mortgage lending contribution to the mortgage meltdown and the financial crisis. Community banks common sense relationship lending and not participating in abusive and predatory lending practices. Community banks thriving on the strength of their reputations and incentive to make fair and reasonable loans. No need for prescriptive regulations to compel community banks to do the right thing for their customers.

Curb imprudent lending practices. Not impacting responsible community bank loan products designed to meet the diverse needs of their customers, including borrowers with special needs and circumstances, first-time homebuyers, borrowers in rural and underserved areas, and low-to-moderate income borrowers. Regulators recognition of the difference between the non-traditional lending practiced by community banks and predatory lending practiced by others.

Community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas should receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs).

Special accommodations for small creditors, flexibility in serving the needs of customers and communities, particularly in rural areas, and the definition of underserved areas to include economically challenged areas.

Reforms to the housing GSEs to include the existence of an impartial secondary market for residential mortgages, one that is financially strong and reliable, the need for some government tie to the secondary market to ensure the continued flow of credit and market liquidity during severe economic stress, no limit in full participation by community banks, and a return of private capital.

Additional reforms to include community banks access to sell loans through an independent entity; no appropriation of community bank customer data for the purpose of cross selling financial services; maintain the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market; pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed; and no further consolidation of the housing finance system.

Stop aggressively compelling community banks to repurchase transferred real estate mortgages for technical violations of underwriting agreements that had no bearing on the quality of the loan at the time of underwriting.

Disparate Impact Fair Lending Causes of Action -
Enforcement actions by the Department of Housing and Urban Development (HUD) and the Department of Justice (DOJ) - disparate impact. Additional obligation on community banks to consider such factors as race or national origin in credit decisions, which is specifically precluded by law - untenable situation

Consumer Financial Protection Bureau Reform -
Community banks regulatory relief to serve unique needs of their customers and not hinder new product development and innovation. Community bank flexibility to meet the unique needs of customers and community banks additional and unnecessary regulatory requirements to prevent their serving their communities.

Not a one-size-fits-all approach to CFPB regulations. Community banks not enduring any additional consumer regulatory burden on top of the existing regulatory burden.

Single-Director governance of the CFPB with a five-member commission. Prudential regulators participating with the CFPB in the rule-writing process. The Financial Stability Oversight Council (FSOC) power to veto CFPB rules.

Broad definition of firms that grant credit being subject to the CFPB rules, and their robust supervision and examinations. Focus of any enhanced regulation of financial products on unregulated shadow financial companies. CFPBs efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products. CFPB holding mega banks and financial firms up to the existing standards for compliance with consumer laws, rules and regulations as required by community banks.

Revised definitions in the Ability-to-Repay Qualified Mortgage rules of small creditor and rural areas, and expansion of the definition of underserved areas to include economically challenged areas.

De Novo Community Bank Formation -
Need for newly chartered (de novo) community banks. FDIC inhibiting de novo community bank formation. FDICs current position and a one-size-fits-all supervisory policy for de novos.

Federal Home Loan Bank System -
The Federal Home Loan Banks (FHLBs) partnership with community banks - short-term liquidity, long-term funding and other financial products and providing lendable funds for the local communities. Maintaining the regional structure, special functions and purposes of the FHLBs. The FHLB Systems health, stability and reliability for its members.

FHFAs proposed (2014) revisions to FHLB membership eligibility requirements - impact on the FHLB System and its members including, but not limited to, regulatory burden, member balance sheet management, stability of the System, and continued reliability as a funding partner, future value of FHLB membership and the implications for membership decisions; and impact on housing and community development throughout the System. The proposed rule is also contrary to the will of Congress.

FHLB System reliance as the sole aggregator or securitizer of residential mortgages for community banks, and the FHFAs imposition of an ongoing housing mission asset test on community financial institutions.


Excessive Intervention in Monetary Policy -
The sustained record-low zero interest rate policy (ZIRP) - disproportionate impact on community banks, senior citizens and discourages savings. Record-low interest rates for five years+ does not constitute temporary intervention but long-term and harmful manipulation. The limits to what Fed monetary policy can accomplish, especially given major offsetting negative effects.


Legislation -

Proposed HMDA legislation - (additional data points, exempting banks provided they have less than 250 home mortgage finance transactions; exempting banks from new HMDA requirements not directly authorized by the Dodd-Frank; exempt commercial purpose, home equity lines of credit, reverse mortgages, home improvement loans and repurchased loans from HMDA requirements) (House)

H.R. 650 - Preserving Access to Manufactured Housing Act of 2015 (Amends TILA to exclude mortgage originators from retailers of manufactured housing) (all sections) (House)

H.R. 1731 - National Cyber Security Protection Advancement Act of 2105 (Information sharing, collaboration coordination, preparation, and security improvements and resiliency, reporting) (all sections) (House)

H.R. 1560 - Protecting Cyber Networks Act (Notification procedures, defensive measures, information sharing, monitoring information systems, liability protection) (all sections) (House)

S. 1484 - Financial Regulatory Improvement Act of 2015 (Title 1 community bank regulatory relief measures) (Title 1 - Sections 100-126) (Senate)

S. 1206 - Too Big to Fail, Too Big to Exist Act (addressing too-big-to-fail institutions) (all sections) (Senate)


Comment Letters -

Comment Letter - Illinois House Ways and Means Committee members, reforming tax code regarding tax subsidies for credit unions and Farm Credit System

Comment Letter - CFPB, grace period of enforcement and liability in the implementation of the TRID

Comment Letter - CFPB, data service providers requirement to provide data pertaining to overdraft programs

Comment Letter - Federal Reserve Bank, Office of Comptroller of the Currency, Federal Deposit Insurance Corporation, Regulatory Review under EGRPRA (tiered regulation for community banks, Prompt Corrective Action (PCA), CRA asset thresholds), Docket ID FFIEC-2014-0001

Comment Letter - Farm Credit Administration, corporate governance standards of conduct proposed rule, 12CFR Parts 650, 651, 653 and 655; RIN 3052-AC89


Action Alerts -

H.R. 1233 and S. 812 - Community Lending Enhancement and Regulatory (CLEAR) Relief Act of 2015 (community bank regulatory relief) (all sections) (House and Senate)

S. 1484 - Financial Regulatory Improvement Act of 2015 (Title 1 community bank regulatory relief measures) (Title 1 - Sections 100-126) (Senate)

H.R. 1523 - The Community Bank Access to Capital Act (enhance community bank access to capital) (all sections) (House)

S. 423 - The Privacy Notice Modernization Act (redundant privacy notice relief) (Senate)

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

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Consumer Financial Protection Bureau (CFPB), Federal Reserve System, Farm Credit Administration, Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC)

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

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

​

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

15. General issue area code FIN

16. Specific lobbying issues

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate)

Too-to-Fail -
Reform the financial system. The severity of a future financial crisis. The perception and reality of too-big-to-fail. Taxpayer bailouts of mega banks and financial firms.

Mega bank size, complexity and interconnectedness, and candidacy for future bailouts. The number of community banks falling by more than half (currently 6,200 institutions) and now represent less than one-fifth of banking professions assets.

Causes of the mortgage meltdown and financial crisis. Protection of the nation and the banking profession from a repeat of massive financial destruction. Taxpayer-funded bailouts of too-big-to-fail banks and financial firms and their numerous violations of the law, often criminal violations.

Effectively management, supervision, discipline, or resolution of too-big-to-fail banks and financial firms. Mega bank multi-trillion dollars financial assistance. Community banks assistance and more than 500 failed community banks. Downsizing too-big-to-fail banks and financial firms.

The fundamental American constitutional right of equal justice under the law applicability when it comes to the mega banks. The U.S. two-tiered system of justice - too-big-to-fail banks and financial firms and everyone else. The Department of Justice (DOJ) - laggard in prosecuting crimes stemming from the financial crisis.

Banking regulators and the DOJ aggressively pursuing actions against community banks, their directors, and officers with board resolutions, MOUs, C&Ds, consent orders, monetary penalties, barring individuals from banking, criminal prosecution, and other actions. No mandatory Prompt Corrective Action (PCA) capital enforcement orders against any bank larger than $30 billion in assets, yet 1,400 PCAs against community banks. Evidence of a clear double standard.

Opponents of downsizing the mega banks (include their paid association cheerleaders) consistently blocking meaningful reforms and obfuscating the issue of too-big-to-fail for the benefit of large members and the detriment of everyone else.

Too-big-to-fail banks, directors, officers, or employees being - too-big-to-manage, too-big-to-regulate, too-big-to-fail, too-big-to-prosecute, too-big-to-jail, too-big-to-change, and clearly too-big-to-behave --- downsize.

Tiered Regulation and Supervision for Community Banks -
The Independent Community Bankers of Americas Plan for Prosperity-

Outsized risks taken by Wall Street mega banks during the financial crisis. The different modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a one-size-fits-all approach. Disproportionate burden of banking laws and regulations on community banks. Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks. Unlevel playing field and a significant competitive disadvantage for community banks.

Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies.

Excessive, redundant and costly regulations. Regulatory accountability. Community banks dedicating resources to promoting economic growth. Steady increase in regulations over many decades. Regulatory threats to community banks and their communities.

The Plan for Prosperity regarding:
Basel III original intent.
additional capital for small holding companies - modernize the Federal Reserves Policy Statement.
Securities and Exchange Commission rules.
reforming mortgage lending.
accountability in bank exams by providing an appeals process.
bank oversight and examinations - targeting risks.
annual requirement for redundant privacy notices.
consumer regulation - inclusive and accountable CFPB governance.
arbitrary disparate impact fair lending causes of action.
viability of mutual banks with new charter options.
cost-benefit analysis to justify new rules.
red tape in small business lending - burdensome data collection.
community bank mortgage servicing.
Treasury Assistant Secretary for Community Banks.
subchapter S constraints.
five-year loss carryback - support for lending during economic downturns.
risk targeting in the Volcker Rule.

Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks.

Credit Union Taxation and Expansion of Powers -
Credit unions now indistinguishable from community banks, grown to control a significant share of the banking services market. Original business model now outdated. Credit unions strayed from founding purpose of serving individuals of modest means and with a common bond. Same financial services as community banks. Federal tax-exempt status, in exchange for serving their original mission is no longer justified. Credit unions should pay their fair share of income taxes.

Credit unions not adhering to a common bond or operating within a well-defined local community, neighborhood or rural district.

Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L). The exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks].

The Office of Management and Budget tax expenditure analysis - tax-exemption for credit unions result in loss of tax revenues of $9.46 billion over fiscal years 2014-2018.

Credit union expansion of commercial lending powers - increasing the percentage of assets cap on member business lending (MBL). Loan growth at the expense of tax-paying community banks. Fundamental altering the exclusive member-focused character of credit unions - a condition for their original tax exemption.

Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts. The same Call Report filing requirements for credit unions as those imposed on community banks.

Tax subsidy and level the playing field between credit unions and tax-paying community banks.

Farm Credit System -
Expansionist agenda of the Farm Credit System (FCS). FCS almost the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status. Tax advantages - unfair competitive advantage. Follow narrow historic mission - abolish or be subject to taxation and oversight and regulation.

Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives.

Support and cooperation of Farm Credit Administration (FCA) - FCS straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities. FCS significant systemic and taxpayer bail-out risks.

The FCS (only GSE) in active competition with community banks. Public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks).

Funding and tax benefits impact on community banks. FCS not following its narrow historical mission. Follow narrow mission or abolish System. Abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity.

FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight.

Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks.

Enhanced Cyber, Data and Payment Card Security -
Establish a federal data security standard and notice requirement for all entities that store consumer data comparable to the Gramm-Leach-Bliley Act (GLBA) standards that apply to community banks. Shifting the liability for all costs associated with the data breach - including fraud losses and the cost of card reissuance - to the party that caused the breach.

Consumer Financial Protection Bureau Mortgage Lending and Housing Finance Reform -
Imprudent mortgage lending contribution to the mortgage meltdown and the financial crisis. Community banks common sense relationship lending and not participating in abusive and predatory lending practices. Community banks thriving on the strength of their reputations and incentive to make fair and reasonable loans. No need for prescriptive regulations to compel community banks to do the right thing for their customers.

Curb imprudent lending practices. Not impacting responsible community bank loan products designed to meet the diverse needs of their customers, including borrowers with special needs and circumstances, first-time homebuyers, borrowers in rural and underserved areas, and low-to-moderate income borrowers. Regulators recognition of the difference between the non-traditional lending practiced by community banks and predatory lending practiced by others.

Community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas should receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs).

Special accommodations for small creditors, flexibility in serving the needs of customers and communities, particularly in rural areas, and the definition of underserved areas to include economically challenged areas.

Reforms to the housing GSEs to include the existence of an impartial secondary market for residential mortgages, one that is financially strong and reliable, the need for some government tie to the secondary market to ensure the continued flow of credit and market liquidity during severe economic stress, no limit in full participation by community banks, and a return of private capital.

Additional reforms to include community banks access to sell loans through an independent entity; no appropriation of community bank customer data for the purpose of cross selling financial services; maintain the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market; pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed; and no further consolidation of the housing finance system.

Stop aggressively compelling community banks to repurchase transferred real estate mortgages for technical violations of underwriting agreements that had no bearing on the quality of the loan at the time of underwriting.

Disparate Impact Fair Lending Causes of Action -
Enforcement actions by the Department of Housing and Urban Development (HUD) and the Department of Justice (DOJ) - disparate impact. Additional obligation on community banks to consider such factors as race or national origin in credit decisions, which is specifically precluded by law - untenable situation

Consumer Financial Protection Bureau Reform -
Community banks regulatory relief to serve unique needs of their customers and not hinder new product development and innovation. Community bank flexibility to meet the unique needs of customers and community banks additional and unnecessary regulatory requirements to prevent their serving their communities.

Not a one-size-fits-all approach to CFPB regulations. Community banks not enduring any additional consumer regulatory burden on top of the existing regulatory burden.

Single-Director governance of the CFPB with a five-member commission. Prudential regulators participating with the CFPB in the rule-writing process. The Financial Stability Oversight Council (FSOC) power to veto CFPB rules.

Broad definition of firms that grant credit being subject to the CFPB rules, and their robust supervision and examinations. Focus of any enhanced regulation of financial products on unregulated shadow financial companies. CFPBs efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products. CFPB holding mega banks and financial firms up to the existing standards for compliance with consumer laws, rules and regulations as required by community banks.

Revised definitions in the Ability-to-Repay Qualified Mortgage rules of small creditor and rural areas, and expansion of the definition of underserved areas to include economically challenged areas.

De Novo Community Bank Formation -
Need for newly chartered (de novo) community banks. FDIC inhibiting de novo community bank formation. FDICs current position and a one-size-fits-all supervisory policy for de novos.

Federal Home Loan Bank System -
The Federal Home Loan Banks (FHLBs) partnership with community banks - short-term liquidity, long-term funding and other financial products and providing lendable funds for the local communities. Maintaining the regional structure, special functions and purposes of the FHLBs. The FHLB Systems health, stability and reliability for its members.

FHFAs proposed (2014) revisions to FHLB membership eligibility requirements - impact on the FHLB System and its members including, but not limited to, regulatory burden, member balance sheet management, stability of the System, and continued reliability as a funding partner, future value of FHLB membership and the implications for membership decisions; and impact on housing and community development throughout the System. The proposed rule is also contrary to the will of Congress.

FHLB System reliance as the sole aggregator or securitizer of residential mortgages for community banks, and the FHFAs imposition of an ongoing housing mission asset test on community financial institutions.

Excessive Intervention in Monetary Policy -
The sustained record-low zero interest rate policy (ZIRP) - disproportionate impact on community banks, senior citizens and discourages savings. Record-low interest rates for five years+ does not constitute temporary intervention but long-term and harmful manipulation. The limits to what Fed monetary policy can accomplish, especially given major offsetting negative effects.


Legislation -

Proposed HMDA legislation - (additional data points, exempting banks provided they have less than 250 home mortgage finance transactions; exempting banks from new HMDA requirements not directly authorized by the Dodd-Frank; exempt commercial purpose, home equity lines of credit, reverse mortgages, home improvement loans and repurchased loans from HMDA requirements) (House)

H.R. 650 - Preserving Access to Manufactured Housing Act of 2015 (Amends TILA to exclude mortgage originators from retailers of manufactured housing) (all sections) (House)

H.R. 1731 - National Cyber Security Protection Advancement Act of 2105 (Information sharing, collaboration coordination, preparation, and security improvements and resiliency, reporting) (all sections) (House)

H.R. 1560 - Protecting Cyber Networks Act (Notification procedures, defensive measures, information sharing, monitoring information systems, liability protection) (all sections) (House)

S. 1484 - Financial Regulatory Improvement Act of 2015 (Title 1 community bank regulatory relief measures) (Title 1 - Sections 100-126) (Senate)

S. 1206 - Too Big to Fail, Too Big to Exist Act (addressing too-big-to-fail institutions) (all sections) (Senate)


Comment Letters -

Comment Letter - Illinois House Ways and Means Committee members, reforming tax code regarding tax subsidies for credit unions and Farm Credit System

Comment Letter - CFPB, grace period of enforcement and liability in the implementation of the TRID

Comment Letter - CFPB, data service providers requirement to provide data pertaining to overdraft programs

Comment Letter - Federal Reserve Bank, Office of Comptroller of the Currency, Federal Deposit Insurance Corporation, Regulatory Review under EGRPRA (tiered regulation for community banks, Prompt Corrective Action (PCA), CRA asset thresholds), Docket ID FFIEC-2014-0001

Comment Letter - Farm Credit Administration, corporate governance standards of conduct proposed rule, 12CFR Parts 650, 651, 653 and 655; RIN 3052-AC89


Action Alerts -

H.R. 1233 and S. 812 - Community Lending Enhancement and Regulatory (CLEAR) Relief Act of 2015 (community bank regulatory relief) (all sections) (House and Senate)

S. 1484 - Financial Regulatory Improvement Act of 2015 (Title 1 community bank regulatory relief measures) (Title 1 - Sections 100-126) (Senate)

H.R. 1523 - The Community Bank Access to Capital Act (enhance community bank access to capital) (all sections) (House)

S. 423 - The Privacy Notice Modernization Act (redundant privacy notice relief) (Senate)

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

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Consumer Financial Protection Bureau (CFPB), Farm Credit Administration, Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Office of the Comptroller of the Currency (OCC)

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

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

​

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

15. General issue area code AGR

16. Specific lobbying issues

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate)

Farm Credit System -
Expansionist agenda of the Farm Credit System (FCS). FCS almost the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status. Tax advantages - unfair competitive advantage. Follow narrow historic mission - abolish or be subject to taxation and oversight and regulation.

Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives.

Support and cooperation of Farm Credit Administration (FCA) - FCS straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities. FCS significant systemic and taxpayer bail-out risks.

The FCS (only GSE) in active competition with community banks. Public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks).

Funding and tax benefits impact on community banks. FCS not following its narrow historical mission. Follow narrow mission or abolish System. Abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity.

FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight.

Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks.

Revised definitions in the Ability-to-Repay Qualified Mortgage rules of small creditor and rural areas, and expansion of the definition of underserved areas to include economically challenged areas. (House and Senate)


Comment Letters -

Comment Letter - Illinois House Ways and Means Committee members, reforming tax code regarding tax subsidies for credit unions and Farm Credit System

Comment Letter - Farm Credit Administration, corporate governance standards of conduct proposed rule, 12CFR Parts 650, 651, 653 and 655; RIN 3052-AC89

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

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Farm Credit Administration

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

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

​

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

15. General issue area code CSP

16. Specific lobbying issues

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate)

Consumer Financial Protection Bureau Mortgage Lending and Housing Finance Reform -
Imprudent mortgage lending contribution to the mortgage meltdown and the financial crisis. Community banks common sense relationship lending and not participate in abusive and predatory lending practices. Community banks thriving on the strength of their reputations and incentive to make fair and reasonable loans. No need for prescriptive regulations to compel community banks to do the right thing for their customers.

Curb imprudent lending practices. Not impacting responsible community bank loan products designed to meet the diverse needs of their customers, including borrowers with special needs and circumstances, first-time homebuyers, borrowers in rural and underserved areas, and low-to-moderate income borrowers. Regulators recognition of the difference between the non-traditional lending practiced by community banks and predatory lending practiced by others.

Community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas should receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs).

Special accommodations for small creditors, flexibility in serving the needs of customers and communities, particularly in rural areas, and the definition of underserved areas to include economically challenged areas.

Reforms to the housing GSEs to include the existence of an impartial secondary market for residential mortgages, one that is financially strong and reliable, the need for some government tie to the secondary market to ensure the continued flow of credit and market liquidity during severe economic stress, no limit in full participation by community banks, and a return of private capital.

Additional reforms to include community banks access to sell loans through an independent entity; no appropriation of community bank customer data for the purpose of cross selling financial services; maintain the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market; pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed; and no further consolidation of the housing finance system.

Stop aggressively compelling community banks to repurchase transferred real estate mortgages for technical violations of underwriting agreements that had no bearing on the quality of the loan at the time of underwriting.

Disparate Impact Fair Lending Causes of Action -
Enforcement actions by the Department of Housing and Urban Development (HUD) and the Department of Justice (DOJ) - disparate impact. Additional obligation on community banks to consider such factors as race or national origin in credit decisions, which is specifically precluded by law - untenable situation.

Consumer Financial Protection Bureau Reform -
Community banks regulatory relief to serve unique needs of their customers and not hinder new product development and innovation. Community bank flexibility to meet the unique needs of customers and community banks additional and unnecessary regulatory requirements to prevent their serving their communities.

Not a one-size-fits-all approach to CFPB regulations. Community banks not enduring any additional consumer regulatory burden on top of the existing regulatory burden.

Single-Director governance of the CFPB with a five-member commission. Prudential regulators participating with the CFPB in the rule-writing process. The Financial Stability Oversight Council (FSOC) power to veto CFPB rules.

Broad definition of firms that grant credit being subject to the CFPB rules, and their robust supervision and examinations. Focus of any enhanced regulation of financial products on unregulated shadow financial companies. CFPBs efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products. CFPB holding mega banks and financial firms up to the existing standards for compliance with consumer laws, rules and regulations as required by community banks.

Federal Home Loan Bank System -
The Federal Home Loan Banks (FHLBs) partnership with community banks - short-term liquidity, long-term funding and other financial products and providing lendable funds for the local communities. Maintaining the regional structure, special functions and purposes of the FHLBs. The FHLB Systems health, stability and reliability for its members.

FHFAs proposed (2014) revisions to FHLB membership eligibility requirements - impact on the FHLB System and its members including, but not limited to, regulatory burden, member balance sheet management, stability of the System, and continued reliability as a funding partner, future value of FHLB membership and the implications for membership decisions; and impact on housing and community development throughout the System. The proposed rule is also contrary to the will of Congress.

FHLB System reliance as the sole aggregator or securitizer of residential mortgages for community banks, and the FHFAs imposition of an ongoing housing mission asset test on community financial institutions.

Excessive Intervention in Monetary Policy -
The sustained record-low zero interest rate policy (ZIRP) - disproportionate impact on community banks, senior citizens and discourages savings. Record-low interest rates for five years+ does not constitute temporary intervention but long-term and harmful manipulation. The limits to what Fed monetary policy can accomplish, especially given major offsetting negative effects.

Revised definitions in the Ability-to-Repay Qualified Mortgage rules of small creditor and rural areas, and expansion of the definition of underserved areas to include economically challenged areas. (House and Senate)

Proposed HMDA legislation - (additional data points, exempting banks provided they have less than 250 home mortgage finance transactions; exempting banks from new HMDA requirements not directly authorized by the Dodd-Frank; exempt commercial purpose, home equity lines of credit, reverse mortgages, home improvement loans and repurchased loans from HMDA requirements) (House)


Legislation -

H.R. 650 - Preserving Access to Manufactured Housing Act of 2015 (Amends TILA to exclude mortgage originators from retailers of manufactured housing) (all sections) (House)

H.R. 1731 - National Cyber Security Protection Advancement Act of 2105 (Information sharing, collaboration coordination, preparation, and security improvements and resiliency, reporting) (all sections) (House)

H.R. 1560 - Protecting Cyber Networks Act (Notification procedures, defensive measures, information sharing, monitoring information systems, liability protection) (all sections) (House)

S. 1484 - Financial Regulatory Improvement Act of 2015 (Title 1 community bank regulatory relief measures) (Title 1 - Sections 100-126) (Senate)


Comment Letters -

Comment Letter - CFPB, grace period of enforcement and liability in the implementation of the TRID

Comment Letter - CFPB, data service providers requirement to provide data pertaining to overdraft programs

Comment Letter - Federal Reserve Bank, Office of Comptroller of the Currency, Federal Deposit Insurance Corporation, Regulatory Review under EGRPRA (tiered regulation for community banks, Prompt Corrective Action (PCA), CRA asset thresholds), Docket ID FFIEC-2014-0001

Action Alerts -

S. 423 - The Privacy Notice Modernization Act (redundant privacy notice relief) (Senate)

H.R. 1233 and S. 812 - Community Lending Enhancement and Regulatory (CLEAR) Relief Act of 2015 (community bank regulatory relief) (all sections) (House and Senate)

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

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

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

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

​

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

15. General issue area code SMB

16. Specific lobbying issues

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate)

Tiered Regulation and Supervision for Community Banks -
The Independent Community Bankers of Americas Plan for Prosperity-

Outsized risks taken by Wall Street mega banks during the financial crisis. The different modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a one-size-fits-all approach. Disproportionate burden of banking laws and regulations on community banks. Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks. Unlevel playing field and a significant competitive disadvantage for community banks.

Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies.

Excessive, redundant and costly regulations. Regulatory accountability. Community banks dedicating resources to promoting economic growth. Steady increase in regulations over many decades. Regulatory threats to community banks and their communities.

The Plan for Prosperity regarding:
Basel III original intent.
additional capital for small holding companies - modernize the Federal Reserves Policy Statement.
Securities and Exchange Commission rules.
reforming mortgage lending.
accountability in bank exams by providing an appeals process.
bank oversight and examinations - targeting risks.
annual requirement for redundant privacy notices.
consumer regulation - inclusive and accountable CFPB governance.
arbitrary disparate impact fair lending causes of action.
viability of mutual banks with new charter options.
cost-benefit analysis to justify new rules.
red tape in small business lending - burdensome data collection.
community bank mortgage servicing.
Treasury Assistant Secretary for Community Banks.
subchapter S constraints.
five-year loss carryback - support for lending during economic downturns.
risk targeting in the Volcker Rule.

Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks.

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

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES

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

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

​

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

15. General issue area code TAX

16. Specific lobbying issues

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate)

Credit Union Taxation and Expansion of Powers -
Credit unions now indistinguishable from community banks, grown to control a significant share of the banking services market. Original business model now outdated. Credit unions strayed from founding purpose of serving individuals of modest means and with a common bond. Same financial services as community banks. Federal tax-exempt status, in exchange for serving their original mission is no longer justified. Credit unions should pay their fair share of income taxes.

Credit unions not adhering to a common bond or operating within a well-defined local community, neighborhood or rural district.

Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L). The exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks].

The Office of Management and Budget tax expenditure analysis - tax-exemption for credit unions result in loss of tax revenues of $9.46 billion over fiscal years 2014-2018.

Credit union expansion of commercial lending powers - increasing the percentage of assets cap on member business lending (MBL). Loan growth at the expense of tax-paying community banks. Fundamental altering the exclusive member-focused character of credit unions - a condition for their original tax exemption.

Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts. The same Call Report filing requirements for credit unions as those imposed on community banks.

Tax subsidy and level the playing field between credit unions and tax-paying community banks.

Farm Credit System -
Expansionist agenda of the Farm Credit System (FCS). FCS almost the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status. Tax advantages - unfair competitive advantage. Follow narrow historic mission - abolish or be subject to taxation and oversight and regulation.

Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives.

Support and cooperation of Farm Credit Administration (FCA) - FCS straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities. FCS significant systemic and taxpayer bail-out risks.

The FCS (only GSE) in active competition with community banks. Public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks).

Funding and tax benefits impact on community banks. FCS not following its narrow historical mission. Follow narrow mission or abolish System. Abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity.

FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight.

Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks.

Tiered Regulation and Supervision for Community Banks -
The Independent Community Bankers of Americas Plan for Prosperity-

Outsized risks taken by Wall Street mega banks during the financial crisis. The different modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a one-size-fits-all approach. Disproportionate burden of banking laws and regulations on community banks. Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks. Unlevel playing field and a significant competitive disadvantage for community banks.

Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies.

Excessive, redundant and costly regulations. Regulatory accountability. Community banks dedicating resources to promoting economic growth. Steady increase in regulations over many decades. Regulatory threats to community banks and their communities.

The Plan for Prosperity regarding:
Basel III original intent.
additional capital for small holding companies - modernize the Federal Reserves Policy Statement.
Securities and Exchange Commission rules.
reforming mortgage lending.
accountability in bank exams by providing an appeals process.
bank oversight and examinations - targeting risks.
annual requirement for redundant privacy notices.
consumer regulation - inclusive and accountable CFPB governance.
arbitrary disparate impact fair lending causes of action.
viability of mutual banks with new charter options.
cost-benefit analysis to justify new rules.
red tape in small business lending - burdensome data collection.
community bank mortgage servicing.
Treasury Assistant Secretary for Community Banks.
subchapter S constraints.
five-year loss carryback - support for lending during economic downturns.
risk targeting in the Volcker Rule.

Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks.

Comment Letters -

Comment Letter - Illinois House Ways and Means Committee members, reforming tax code regarding tax subsidies for credit unions and Farm Credit System

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

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES

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

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

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

20. Client new address

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

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

LOBBYIST UPDATE

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

ISSUE UPDATE

24. General lobbying issue that no longer pertains

AFFILIATED ORGANIZATIONS

25. Add the following affiliated organization(s)

Internet Address:

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

FOREIGN ENTITIES

27. Add the following foreign entities:

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