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; supports a transparent, fair and efficient mechanism for funding agency operations; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance; H.R. 133, the Consolidated Appropriations Act of 2021; support efforts to correct gaps in BSA/AML regulations and CVC reporting; urges FinCEN to allow for additional time for stakeholder comments and providing a reasonable implementation period for new requirements; support CDCs recommendation that workers in the finance industry be included as essential workers; support dedicated cash window to include all credit unions; support communication on relevant information regarding the First and Second Draw PPP loans; supports HUDs proposal to amend the FHAs regulations to allow borrowers of single-family properties and other insured properties the option to purchase private flood insurance on FHA-insured mortgages for properties located in Special Flood Hazard Areas (SFHAs) to satisfy the mandatory purchase requirements of the Flood Disaster Protection Act of 1973; support additional investment authorities for credit unions to manage this influx of deposits; support access to credit for small businesses impacted by the COVID-19; support loan maturity extension; FCU Act should allow all credit unions to add underserved areas to their fields of membership; support ESIGN Modernization; expand section 4016 of the CARES Act; parity for credit unions for protections under section 4008 of the CARES Act; expand section 4014 of the CARES Act; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; caution you against making major changes to bankruptcy law; NCUA should (1) immediately issue an interim final rule to provide credit unions parity with recent changes made to community bank threshold standards or offer a different evaluation of credit union assets; and (2) coordinate with the CFPB to provide uniformity in the calculation of credit union assets for purposes of the $10 billion threshold; support efforts to provide flexibility for FCUs to operate their mortgage loan businesses and provide FICUs with another avenue to sell their mortgage servicing rights; support proposed rule to remove the prohibition on the capitalization of interest under Appendix B to Part 741; support authorization of a second PPP loan, simplifying loan forgiveness for PPP loans under the $150,000 threshold and repealing the deduction of EIDL advances from the PPP loan forgiveness amount; Consumer Access to Financial Records; RIN: 3170-AA78; avoid implementing section 1033 in a way that impairs a credit unions ability to protect its members data from the risk of theft or abuse; support update to Chartering and Field of Membership and Shared Facility Requirements, support modernization of the Manual by including online and mobile banking platforms in the definition of service facility; Exempt credit unions from the CECL standard; support proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy; urge the SBA to reduce loan forgiveness review times, focus reviews on larger and riskier loans, and provide consistent processing; opposes any premium that is the direct result of excess share growth rather than material weakness in the Share insurance fund because year-end financials of the SIF reflect the overall strength of the fund; support targeted efforts to help small businesses in these trying times, especially minority- and women-owned businesses that have struggled to access funding; support Homeowner Assistance Fund bill; Ensure that there is a liability shield for businesses that follow the law, protect their employees; raise concerns about legislatively mandated blanket loan forbearance; supports the NCUA having express authority to exempt federally-insured credit unions (FICUs) from suspicious activity report (SAR) requirements; support the FHFAs acknowledgement of the need to modernize appraisals by creating a more streamlined and accurate valuation process, requests that the FHFA require consistent practices among individual appraisers; continue to allow Automated Valuation Models (AVMs) and appraisal waivers to be used for all low-risk mortgage loans; and update the AVM technology to allow AVMs to be used in rural areas to improve appraisal turnaround times; H.R. 1319, the American Rescue Plan Act of 2021; Provide temporary capital flexibility for the National Credit Union Administration (NCUA) and credit unions, such as a reduction in the level at which credit unions are considered well capitalized; Urges Support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; support relief from the member business loan (MBL) cap; requests that the NCUA consolidate its supervisory guidance into fewer letterheads, improve its website to increase usability, and release timely cybersecurity risk alerts; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; support allowing the GSEs to rebuild capital and ensuring the GSEs are in a safe and sound financial condition before exiting conservatorship to guarantee a healthy and sustainable secondary mortgage market; ensure that any incentives for excessive risk-taking are eliminated but the FHFA should be encouraging the GSEs to focus on increasing opportunities for very-low, low-, and moderate income individuals to purchase a home; support Economic Aid to Hard-Hit Small Businesses, Nonprofits and Venues Act (Economic Aid Act) as part of the year-end stimulus package; support expansion for SBA Interim Final Rule that implements a revised PPP loan calculation formula for Schedule C filers; reject and urge against pilot program for USPS postal banking; support American Rescue Plan Act assistance; exclude credit union member business loans made in response to COVID-19 relief from the credit union member business lending (MBL) cap; urge the Bureau to initiate a rulemaking and exercise its supervisory authority over fintech companies that fall within the scope of a larger participant in the consumer financial services market; urge CFPB to coordinate with the FHFA as it examines its authority to regulate and supervise non-bank mortgage companies; Risk-Based Net Worth-COVID-19 Regulatory Relief; reject ICBAs ongoing attacks on the credit unions; support bank-credit union mergers.

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; supports a transparent, fair and efficient mechanism for funding agency operations; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance; H.R. 133, the Consolidated Appropriations Act of 2021; support efforts to correct gaps in BSA/AML regulations and CVC reporting; urges FinCEN to allow for additional time for stakeholder comments and providing a reasonable implementation period for new requirements; support CDCs recommendation that workers in the finance industry be included as essential workers; support dedicated cash window to include all credit unions; support communication on relevant information regarding the First and Second Draw PPP loans; supports HUDs proposal to amend the FHAs regulations to allow borrowers of single-family properties and other insured properties the option to purchase private flood insurance on FHA-insured mortgages for properties located in Special Flood Hazard Areas (SFHAs) to satisfy the mandatory purchase requirements of the Flood Disaster Protection Act of 1973; support additional investment authorities for credit unions to manage this influx of deposits; support access to credit for small businesses impacted by the COVID-19; support loan maturity extension; FCU Act should allow all credit unions to add underserved areas to their fields of membership; support ESIGN Modernization; expand section 4016 of the CARES Act; parity for credit unions for protections under section 4008 of the CARES Act; expand section 4014 of the CARES Act; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; caution you against making major changes to bankruptcy law; NCUA should (1) immediately issue an interim final rule to provide credit unions parity with recent changes made to community bank threshold standards or offer a different evaluation of credit union assets; and (2) coordinate with the CFPB to provide uniformity in the calculation of credit union assets for purposes of the $10 billion threshold; support efforts to provide flexibility for FCUs to operate their mortgage loan businesses and provide FICUs with another avenue to sell their mortgage servicing rights; support proposed rule to remove the prohibition on the capitalization of interest under Appendix B to Part 741; support authorization of a second PPP loan, simplifying loan forgiveness for PPP loans under the $150,000 threshold and repealing the deduction of EIDL advances from the PPP loan forgiveness amount; Consumer Access to Financial Records; RIN: 3170-AA78; avoid implementing section 1033 in a way that impairs a credit unions ability to protect its members data from the risk of theft or abuse; support update to Chartering and Field of Membership and Shared Facility Requirements, support modernization of the Manual by including online and mobile banking platforms in the definition of service facility; Exempt credit unions from the CECL standard; support proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy; urge the SBA to reduce loan forgiveness review times, focus reviews on larger and riskier loans, and provide consistent processing; opposes any premium that is the direct result of excess share growth rather than material weakness in the Share insurance fund because year-end financials of the SIF reflect the overall strength of the fund; support targeted efforts to help small businesses in these trying times, especially minority- and women-owned businesses that have struggled to access funding; support Homeowner Assistance Fund bill; Ensure that there is a liability shield for businesses that follow the law, protect their employees; raise concerns about legislatively mandated blanket loan forbearance; supports the NCUA having express authority to exempt federally-insured credit unions (FICUs) from suspicious activity report (SAR) requirements; support the FHFAs acknowledgement of the need to modernize appraisals by creating a more streamlined and accurate valuation process, requests that the FHFA require consistent practices among individual appraisers; continue to allow Automated Valuation Models (AVMs) and appraisal waivers to be used for all low-risk mortgage loans; and update the AVM technology to allow AVMs to be used in rural areas to improve appraisal turnaround times; H.R. 1319, the American Rescue Plan Act of 2021; Provide temporary capital flexibility for the National Credit Union Administration (NCUA) and credit unions, such as a reduction in the level at which credit unions are considered well capitalized; Urges Support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; support relief from the member business loan (MBL) cap; requests that the NCUA consolidate its supervisory guidance into fewer letterheads, improve its website to increase usability, and release timely cybersecurity risk alerts; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; support allowing the GSEs to rebuild capital and ensuring the GSEs are in a safe and sound financial condition before exiting conservatorship to guarantee a healthy and sustainable secondary mortgage market; ensure that any incentives for excessive risk-taking are eliminated but the FHFA should be encouraging the GSEs to focus on increasing opportunities for very-low, low-, and moderate income individuals to purchase a home; support Economic Aid to Hard-Hit Small Businesses, Nonprofits and Venues Act (Economic Aid Act) as part of the year-end stimulus package; support expansion for SBA Interim Final Rule that implements a revised PPP loan calculation formula for Schedule C filers; reject and urge against pilot program for USPS postal banking; support American Rescue Plan Act assistance; exclude credit union member business loans made in response to COVID-19 relief from the credit union member business lending (MBL) cap; urge the Bureau to initiate a rulemaking and exercise its supervisory authority over fintech companies that fall within the scope of a larger participant in the consumer financial services market; urge CFPB to coordinate with the FHFA as it examines its authority to regulate and supervise non-bank mortgage companies; Risk-Based Net Worth-COVID-19 Regulatory Relief; reject ICBAs ongoing attacks on the credit unions; support bank-credit union mergers.

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