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

Financial Institutions/Investments/Securities FIN

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

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

Bills named: H.R. 2311 (117th), H.R. 1471 (117th), S. 3441 (117th), H.R. 963 (117th), H.R. 7412 (117th), H.R. 1996 (117th), H.R. 3323 (117th), H.R. 3076 (117th), S. 4004 (117th), S. 1684 (117th), S. 910 (117th), S. 3745 (117th), H.R. 5189 (117th), S. 762 (117th), H.R. 7003 (117th)

Taxation/Internal Revenue Code TAX

Protect the credit union tax exemption

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

Banking BAN

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

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

Bills named: S. 762 (117th), H.R. 5189 (117th), H.R. 3076 (117th), H.R. 3323 (117th), S. 910 (117th), H.R. 1996 (117th), H.R. 7003 (117th), H.R. 1471 (117th), S. 1684 (117th), H.R. 2311 (117th), S. 3441 (117th), H.R. 7412 (117th), S. 3745 (117th), S. 4004 (117th), H.R. 963 (117th)