NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS (FKA NAT'L ASSN OF FEDERAL CREDIT UNIONS) for NATIONAL ASSOCIATION OF FEDERALLY-INSURED CREDIT UNIONS

Banking BAN

Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act

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

Bills named: H.R. 6116 (116th), H.R. 7777 (116th), H.R. 6395 (116th), S. 4159 (116th), S. 4117 (116th), H.R. 2305 (116th), H.R. 6800 (116th), S. 2834 (116th), S. 4049 (116th), H.R. 7914 (116th), H.R. 7913 (116th), H.R. 925 (116th)

Financial Institutions/Investments/Securities FIN

Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act

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

Bills named: S. 2834 (116th), S. 4049 (116th), H.R. 6800 (116th), H.R. 7777 (116th), H.R. 6395 (116th), H.R. 2305 (116th), H.R. 7914 (116th), H.R. 7913 (116th), H.R. 925 (116th), H.R. 6116 (116th), S. 4159 (116th), S. 4117 (116th)

Taxation/Internal Revenue Code TAX

Protect the credit union tax exemption.

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