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; 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.

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

Bills named: H.R. 1319 (117th), H.R. 1471 (117th), H.R. 133 (117th)

Financial Institutions/Investments/Securities FIN

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.

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

Bills named: H.R. 1471 (117th), H.R. 1319 (117th), H.R. 133 (117th)

Taxation/Internal Revenue Code TAX

Protect the credit union tax exemption

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