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

Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure that credit unions have unfettered access to the secondary mortgage market based on loan quality rather than quantity; Member Business Lending - raise the arbitrary cap, raise the de minimis exclusion; exempt loans to veterans from the definition of MBL, and exclude non-owner occupied, 1-4-family dwellings from the calculation of the cap on credit union member business loans (H.R. 389 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).

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

Natl Credit Union Administration (NCUA), Small Business Administration (SBA), Defense - Dept of (DOD), Homeland Security - Dept of (DHS), Federal Reserve System, Treasury - Dept of, Federal Deposit Insurance Corporation (FDIC), Securities & Exchange Commission (SEC), Housing & Urban Development - Dept of (HUD), Office of the Comptroller of the Currency (OCC), Government Accountability Office (GAO), White House Office, Federal Housing Finance Agency (FHFA), Consumer Financial Protection Bureau (CFPB), Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Commodity Futures Trading Commission (CFTC), Justice - Dept of (DOJ), U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Federal Communications Commission (FCC), Labor - Dept of (DOL)

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

Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure that credit unions have unfettered access to the secondary mortgage market based on loan quality rather than quantity; Member Business Lending - raise the arbitrary cap, raise the de minimis exclusion; exempt loans to veterans from the definition of MBL, and exclude non-owner occupied, 1-4-family dwellings from the calculation of the cap on credit union member business loans (H.R. 389 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).

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

Natl Credit Union Administration (NCUA), Small Business Administration (SBA), Defense - Dept of (DOD), Homeland Security - Dept of (DHS), Federal Reserve System, Treasury - Dept of, Federal Deposit Insurance Corporation (FDIC), Securities & Exchange Commission (SEC), Housing & Urban Development - Dept of (HUD), Office of the Comptroller of the Currency (OCC), Government Accountability Office (GAO), White House Office, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Commodity Futures Trading Commission (CFTC), Justice - Dept of (DOJ), U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Federal Housing Finance Agency (FHFA), Consumer Financial Protection Bureau (CFPB), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Federal Communications Commission (FCC), Labor - Dept of (DOL)

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

Protect the credit union tax exemption

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

Internal Revenue Service (IRS), Natl Credit Union Administration (NCUA), Treasury - Dept of, White House Office, U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Federal Trade Commission (FTC), Federal Reserve System, Office of Management & Budget (OMB)

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

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

​

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

20. Client new address

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

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

LOBBYIST UPDATE

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

ISSUE UPDATE

24. General lobbying issue that no longer pertains

AFFILIATED ORGANIZATIONS

25. Add the following affiliated organization(s)

Internet Address: https://www.nafcu.org/Tertiary.aspx?id=17818

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