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

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.

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), Veterans Affairs - Dept of (VA)

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

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.

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), Veterans Affairs - Dept of (VA)

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/boardofdirectors

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

CONVICTIONS DISCLOSURE

29. Have any of the lobbyists listed on this report been convicted in a Federal or State Court of an offense involving bribery, extortion, embezzlement, an illegal kickback, tax evasion, fraud, a conflict of interest, making a false statement, perjury, or money laundering?
No Yes